More than two years after the Globally Harmonized System for Classification and Labeling of Chemicals (GHS) Notice of Proposed Rule Making (NPRM) to revise the existing Hazard Communication Standard (HCS) was introduced, OSHA finalized the new rule and significantly amended the 29 CFR, effective May 26, 2012. The revised OSHA HCS (hereafter referred to as HazCom 2012) is based on the 3rd Revised Edition of the Purple Book (the UN’s published guide for GHS) with some content drawn from the 4th Revised Edition.
The U.S. was not an early adopter. New Zealand led the way in 2001, and was quickly followed by a wave of Asia-Pacific nations. The EU adopted its version in 2009. A number of factors extend the timeline for complete global harmonization:
- It’s optional — there is no global mandate.
- Nations can pick and choose which sections in the Purple Book to implement, omitting perceived negative obligations.
- If participating countries have specific data requirements, etc. not specifically called out in the Purple Book, GHS does not restrict inclusion of additional information on labels and safety data sheets (SDSs).
- Most countries have opted for staggered timelines to adopt the GHS, thus easing into implementation
- Purple Book Revisions — Currently, there are four editions of the Purple Book. Participants can apply sections from a combination of versions.
All this may look like the most unharmonized harmonized system in the world, but the intent is to use flexibility for continuous movement toward a true GHS.