MSDSpro Regulatory Services
OSHA Hazard Communication Standard 2012 (OSHA HCS 2012) FAQs
The MSDSpro Regulatory Services division provides SDS and label authoring services for manufacturers who produce and ship their chemical products both domestically (USA) and internationally. These industries include chemical manufacturers and distributors, specialty chemicals/custom blenders, petroleum (oil and gas), polymers and plastics, industrial and medical gases, paints and coatings, and biotechnology/pharmaceutical companies, among others. We provide authoring services for MSDSs (GHS, REACH, OSHA, WHMIS and NOM) and labels (CLP-compliant and workplace labels), among other regulatory documents.
Changing Your Product's GHS Hazard Classification with "HARt"
Will your chemical products remain ‘non-hazardous’ under GHS, or will they trigger an environmental or toxicological hazard? If so, how will you reformulate “greener” products that also meet your customers’ needs? The GHS classification requires a complex calculation to determine the correct rating for the classification system; the 0.1% or 1% cut-off no longer applies. Use the MSDSpro Hazards Assessment Report (HARt) to identify which ingredients in your products trigger GHS hazards (e.g., acute toxicity, respiratory or skin sensitization, carcinogenicity, etc.) and the suggested concentrations to remove those hazards.
Contact MSDSpro Regulatory Services today for details.
OSHA Q&A Session - Update on the HCS alignment with GHS
The GHS is a single, harmonized system for classification of chemicals according to their health, physical, and environmental effects. It also provides harmonized communication elements, including labels and safety data sheets. Last July 11th, the US Department of Labor hosted a Live Q&A Session with OSHA on its final rule to align the current HCS with GHS, now scheduled for September 2011. The GHS implementation period will be announced when the final rule is published.
Per OSHA, companies may opt to classify their products according to GHS TODAY, as long as they also follow the current HCS. The companies must assess whether their chemicals are appropriately classified. During the Q&A session, OSHA also commented on the following:
* Changes in requirements for workplace and secondary container labels
* Inclusion on TLVs and PELs on the new "SDS" (Safety Data Sheet)
* The format of the GHS SDS
Workplace/secondary container labels: while OSHA did not propose any changes in the requirements for workplace labeling, any changes will be announced when the final rule is published.
Inclusion of TLVs and PELs on the new "SDS" (Safety Data Sheet): comments were received from many stakeholders on the value of including TLVs and PELs. OSHA's determination on this issue will be addressed in the final rule.
The format of the GHS SDS: GHS is designed to enable workers of limited literacy in the English language to understand the information provided. As long as the manufacturer's product is appropriately classified under GHS and follows the current HCS, the manufacturer may use the GHS format for its Safety Data Sheets and labels.
Contact MSDSpro Regulatory Services today for help in authoring your GHS SDSs and labels. Read the static version of the Live Q&A Session with OSHA here.
OSHA's Key Facts to Align HCS with GHS
OSHA is proposing to modify the current Hazard Communication Standard (HCS) to align with the provisions of the Globally Harmonzied System of Classification and Labelling of Chemicals (GHS). The HCS requires that chemical manufacturers and importers evaluate the chemicals they produce or import and provide hazard information to downstream employers and workers by putting labels on containers and preparing safety data sheets.
NEW Key HCS & GHS Facts:
1) Number of workers affected by HCS - Over 40 Million
2) Affected Industries - Over 5 Million
3) Annualized Compliance Costs - Approximately $97 Million Per Year
4) GHS Benefits - Increase the quality and consistency of information provided to workers, employers and chemical users by adopting a standardized approach to hazard classification, labels and safety data. Learn MORE
Hazard Determination/Classification - OSHA HCS vs. GHS
A significant difference between the OSHA HCS and GHS is in the evaluation of mixtures. While the HCS allows test data on mixtures to be used for all hazard classes, the GHS criteria for mixtures varies by hazard class. The GHS also allows test data on carcinogens, mutagens and reproductive toxins on a case-by-case basis. A detailed comparison of the GHS to the requirements of the HCS may be found here.
By verifying the current classifications of its products and mixtures today under HCS, REACH-CLP and GHS, North America chemical manufacturers will be well-prepared for OSHA's final ruling on GHS, scheduled for August 2011. Contact MSDSpro Regulatory Services today for details on how to obtain updated regulatory information for the substances and mixtures you produce.
5 Ways to Streamline Automated SDS Distribution
According to OSHA estimates, nearly 1 million Safety Data Sheets will have to be re-authored or updated once the new provisions of the Globally Harmonized System (GHS) take effect in the United States. Specifically, according to OSHA research1, the baseline facts of the Hazard Communication environment are:
* 880,000 hazardous chemicals are used in U.S. workplaces alone
* 5,000,000 workplaces contain chemicals on site
* 40,000,000 workers are affected by the provisions of the Hazard Communication standard (HCS)
So the elephant in the room is, "How are organizations going to efficiently update and distribute nearly 1 million revised safety data sheets to 40 million workers, all in a cost-efficient manner?" Leaving the safety data sheet authoring challenges aside for now, let's focus on the avalanche of documents that is going to bury chemical producers and chemical end users alike in Material Safety Data Sheets (MSDSs) and chemical data.
1) Push or Pull. The provisions of OSHA's current Hazard Communication Standard (HCS) maintain it is the chemical supplier's responsibility to supply the required chemical data information in the form of SDSs and chemical labels to employers. Second, it is the employer's responsibility to provide readily available access to such information to affected employees. Therefore, chemical suppliers must be able to efficiently "push" new and updated chemical safety documents to employers and also support the occasional ad hoc request ("pull") by customers or other end users. It's useful to support both methods, but the main emphasis should be on the right outbound push mechanism and process.
2) Paper or Electronic. Employers have some latitude on how to present chemical safety information to their employees. Some may employ an electronic SDS management system, while others may continue to use paper-based binders. Your SDS Distribution approach should consider not only the physical output, but also the preferred customer method of receiving SDSs, including e-mail, postal mail, or fax. Tying these preferences into the customer records enables an electronic SDS Distribution system to route the proper documents in the proper media on demand.
3) Frequency and Volume. Do you have one or 1,000 MSDSs to circulate? You also should consider the volume of customers. If you have 1,000 documents and 1,000 customers, you could potentially have 1,000,000 distinct mailing events if every customer required every document in a separate transaction. Obviously, managing this via a manual process becomes more challenging as product and customer counts grow. Furthermore, is this a cost-effective means of utilizing internal resources? Service providers specializing in SDS Authoring, Distribution, and Management can often perform SDS publishing and fulfillment for pennies per transaction.
4) Custom vs. Non-proprietary. If your organization builds its own process or system for distributing SDSs, consider which parts should be custom to your organization and which should be non-proprietary to take advantage of economies of scale. Customer, order, and shipment information are probably closely tied to your business, but perhaps the enabling technologies and business processes for communicating related chemical information are not. In this case, leverage distribution networks that are already in place instead of investing the time and money to reinvent the wheel.
5) Supply Chain Integration. A major benefit that can be realized when considering electronic SDS Distribution options is the ability to integrate supply chain systems and SDS authoring systems to your distribution platform. In this case, automated workflow manages the entire process from revision alert to SDS authoring to SDS publishing or from chemical shipment to SDS publishing. Closing the loop offers a "hands free" utopia of chemical data information publishing.
References: Occupational Health & Safety www.ohsonline.com
Sub-Committee Meeting of Experts on the GHS (December 7-9, 2010)
At its 20th session, held in Geneva, Switzerland, the Sub-Committee reviewed the consolidated list of draft amendments to the GHS along with a number of related and new proposals (including several from the United States). The Committee addressed questions related to the classification of chemically unstable gases and gas mixtures, simple asphyxiates, hazard communication for aerosols and gases under pressure, revision of precautionary statements and corrosivity criteria. Practical classification issues, the editorial revision of Chapters 3.2 and 3.3 and the revision of Annexes 1, 2 and 3 of the GHS were addressed as well.
OSHA hosts public meeting on Globally Harmonized System of labeling chemicals (November 15, 2010)
OSHA is inviting interested parties to participate in an open, informal public meeting Nov. 30 to discuss proposals in preparation for the 20th session of the United Nations Subcommittee of Experts on the Globally Harmonized System of Classification and Labeling of Chemicals. The Globally Harmonized System was formally adopted by the United Nations in December 2002. The GHS is a single, harmonized system for classification of chemicals according to their health, physical, and environmental effects. It also provides harmonized communication elements, including labels and safety data sheets.
The public may attend without prior notice a meeting of the U.S. Interagency GHS Coordinating Group hosted by OSHA in the Department of Labor's Frances Perkins Building in Washington, D.C. The purpose of the meeting is to provide interested groups and individuals with an update on GHS-related issues and an opportunity to express their views for consideration in developing U.S. government positions for the upcoming U.N. meeting, which will take place Dec. 7-9 in Geneva, Switzerland. See the Federal Register notice for more information.
GHS - Definition and Current Implementation Status (October 19, 2010)
GHS stands for the Globally Harmonized System of classification and labeling of chemicals. Developed and maintained at United Nations level, GHS provides a basis for uniform physical, environmental, health and safety information on hazardous chemicals at the global level through the harmonization of the classification criteria, labeling rules and guidance on the preparation of Safety Data Sheets. The GHS itself is not a regulation or a standard; rather, it establishes agreed hazard classification and communication provisions with explanatory information on how to apply the system.
To download MSDSpro, LLC's overview presentation on GHS, click here.
To learn the current implementation status of GHS by country, click here.
To read or print the guide to GHS ("The Purple Book"), click here.