The First Step – US Department of Labor issues GHS notice of proposed rulemaking

- By:

Courtesy of The Compliance Center (ICC)

On September 30, the Occupational Safety and Health Administration (OSHA) of the Department of Labor published a Notice of Proposed Rulemaking (NPRM) that starts the long process of introducing the Globally Harmonized System (GHS) into North America.

This Notice (Docket No. OSHA-H022K-2006-0062) proposes to modify OSHA’s current Hazard Communication Standard (HCS) to conform with the system for classification, labeling and safety data sheets proposed by the United Nations. The Globally Harmonized System, found in the UN’s Purple Book, is an attempt to standardize hazard communication for workplace and consumer products on a worldwide basis. This will both improve enhance trade by removing significant variations in international standards, as well as improve hazard communication in parts of the world where few regulations currently exist.

OSHA plans, using this docket, to significantly amend its system of identifying hazardous workplace materials found in 29 CFR 1910.1200. The new system will include:

• Revised classification criteria for determining hazards,
• A new labeling system, that will include standardized signal words, pictograms to depict hazards, and prescribed hazard and precautionary statements,
• A revised and more specific format for material safety data sheets (to be called simply safety data sheets in the new system), and
• Modification of other safety standards, such as those for specific substances, to ensure consistency with the GHS standard.

Revising such a large document as the HCS will take a lot of work on the behalf of industry as well as government. OSHA is currently allowing ninety days for public comment from concerned parties, before starting the process leading to an eventual Final Rulemaking that will create the new system. Companies affected by the HCS need to provide as much input as possible, since there will likely be considerable fine-tuning required to make this system successful. Comments may be made to Docket No. OSHA-H022K-2006-0062 at

How will this affect Canada and Mexico? Of course, as the US is the largest part of the North American trading zone, there will be considerable pressure on those governments to change their own hazard communication standards accordingly. Health Canada is currently looking at amending the WHMIS system and the Hazardous Products Act to conform to GHS, although there has been no date set yet for when these amendments will be seen. Mexico is currently also developing a GHS modification to their own chemical hazard communication laws.

To download a copy of these proposed amendments from the Federal Register, go to ICC will be following the progress of GHS closely – please contact us if you have questions, or would like to know how ICC The Compliance Center can help you implement GHS in your organization.

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