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Are We Out of Tune? Part 2

In Part 1 of this blog, we explored the history behind the Globally Harmonized System (GHS) and the reasons why the potential changes are important to the United States. In Part 2 of this series, we will take a look at a few of these changes to see how they might impact our workplaces.

  • Multiple definitions within the GHS - Revision 7 are being added or revised including combustible dust, gas, liquid, and solid. These additions and changes will bring us in closer agreement with those countries that manufacture and import chemicals into the United States. 
  • Another interesting proposal is the addition of the phrase, “under normal conditions of use and foreseeable emergencies” to the Hazard Classification requirements for chemical manufacturers. This addition would help chemical manufacturers decide what hazards should be identified for the “intended use” of their products and eliminate guessing at all the possible outcomes of the unintended use of their chemical. 
  • In our current version of the GHS, aerosols are treated similarly to compressed gases and there are no specific Signal Words, hazard, or precautionary statements. This revision proposes that aerosols be separated from compressed gases and given their own warnings and statements. The Signal Word for aerosols would be Warning and a Hazard Statement would be added to indicate the danger of heating the container. In addition, two Precautionary Statements (one for Prevention and one under Storage) would give the user guidance on proper handling and storage of aerosol chemicals. 
  • Lastly, there are many changes proposed for the determination of “Health” and “Physical” Hazard categories. While the current rating system spans from “4” (which indicates the lowest level of hazard) to a “1” (highest level of hazard), the criteria can be somewhat vague, and much interpretation was left to the manufacturers’ discretion. Under these proposals, a more precise, “tiered system” of decision making would make their determinations much more accurate and consistent. An example of this expansion is the corrosive effects of chemicals in relation to potential eye damage.

These are just a few of the many changes proposed as part of this potential update to the United States’ Hazard Communication Standard. At this time OSHA has held an Informal Hearing to discuss these updates (September 21, 2021) but it will be some time before the standard will be updated.

Before “decomposing” your written Hazard Communication Program, my advice is to wait until the final rule is published to know the final “score.” With some “concerted” effort on the part of OSHA these updates should make us much more “harmonized” with the rest of the world.

A “red-lined” version of the current standard (all 228 pages) is available here. This document shows all of the proposed changes within their context in the Hazard Communication Standard (HCS).

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