The Globally Harmonized System of Classification and labelling of Chemicals (GHS) has been discussed and has been 'coming soon' for many years, why is it needed? Well the problem is that hazardous chemical substances are routinely and frequently manufactured, created or refined in one country, transported to another and then used in a third, or fourth or fifth country State or Province.
Although the chemical may have the same Hazard Communication Standard (HCS) number everywhere the interpretation of the hazard it represents (and hence the way it must be treated along the way) varies widely. Imagine a chemical substance with a particular Chemical Abstract Number (CAS) and a specific lethal dose value that is simultaneously described as “Non-toxic” in India, “Moderately toxic” in China, “Harmful” in Australia and Europe, “Hazardous” in New Zealand, and “Toxic” in North America! Think of the legal complications and difficulty filing official paperwork for Transportation of Dangerous Goods (TDG) in order to export this substance from one country to another. Then think about the number of different labels required for this product and how to accurately communicate the associated hazards to workers who might use it. In a world dependent on global trade these difficulties seriously undermine economic progress.
The United Nations describes the purpose as follows:
“...it is anticipated that the GHS will:
a) enhance the protection of human health and the environment by providing as internationally comprehensible system for hazard communication;
b) provide a recognised framework for those countries without an existing system (NB for Canada this system is WHMIS, for the US it is the OSHA Hazard Communication Standard , or HCS)
c) reduce the need for testing and evaluation of chemicals;
d) facilitate international trade in chemicals whose hazards have been properly assessed and identified on an international basis”
It was this, and other environmental issues, that world trade representatives sought to address in the early 1990’s. The first draft of the Globally Harmonized System for the Classification and Labelling of Chemicals (GHS) was created and adopted by the United Nations in 2002. Because the gestation period of GHS has been so long it might be easy to dismiss it as a worthy project never to be finished so no attention needs to be paid to it. We think this would be a mistake! Canada and the US are enthusiastically supporting the implementation of GHS and are expected to be early adopters. Even so it may still take some time!
The current version of GHS has been placed online by OSHA at: http://www.osha.gov/dsg/hazcom/ghs.html.
It is this version of GHS that many in Canada expect to be adopted. Health Canada has been given the task of coordinating the Canadian position. Their implementation plans can be seen at:
http://www.hc-sc.gc.ca/cps-spc/alt_formats/pdf/pubs/pest/corp-plan/nafta-alena/jr03-03-0809-eng.pdf.
It is important to understand that WHMIS - Canada’s national system of hazard communication - will not be replaced by GHS. Government documents usually refer to the proposed system as “WHMIS after GHS”. The areas that will see changes include: classification rules, label requirements and information documents (formerly known as Material Safety Data Sheets [MSDS’s]; henceforth to be called Safety Data Sheets [SDS]).
There will be many more classes of hazards under the GHS system and probably covering more substances. It is expected that there will be three general groups and classes within each group as follows:
Physical Hazards – 16 classes
Health Hazards – 10 classes
Environmental Hazards – 2 classes
Furthermore each class may be subdivided into one or more categories. There will also likely be 5 new classes covering: explosives, aspiration hazards, specific target organ toxicity – single exposure, hazardous to the aquatic environment and hazardous to the ozone layer4.
Supplier labels will still be required under the new rules. They should look similar to what we are all used to seeing under WHMIS. It is possible that the specific chemical name will appear under the product identifier and new “signal words” (such as ‘Danger’ or ‘Warning’) will be required to be used as per appropriate regulations. Hopefully, the requirement for the familiar hatched border will be retained in WHMIS after GHS. However OSHA does not presently require hatching for the labels of hazardous substances.
Material Safety Data Sheets (MSDS’s) will be known simply as Safety Data Sheets (SDS’s) in WHMIS after GHS. SDS’s will follow the 16-heading format already adopted by ANSI (American National Standards Institute) and ILO (international Labor Organization). This format is already used for many American products and will help to ensure that the same type of information will be presented in the same order, with the same headings. It is expected that the rules for updating SDS’s will be retained – every 3 years or when new information becomes available.
WHMIS training requirements are more prescriptive than either GHS Training recommendations or the present requirements under OSHA standard 29 CFR 1910. But remember that if products are imported from countries that implement GHS prior to the United States and Canada, employee training may need to begin earlier than expected.
Online Transportation of Dangerous Goods (TDG) Training
Please watch this space to keep pace with the implementation of the GHS.
