The GHS was developed by the United Nations to – in short – get everyone on the same page internationally when it comes to the safe handling of chemicals. It’s intended that one day, everyone that deals with the international sale, transportation, and handling of hazardous chemicals can use standardized labeling and Safety Data Sheet(SDS) system to make handling safer. It’s also so that workplace conditions for employees dealing with these chemicals can minimize chemical exposures and related accidents.
It’s a common misconception that the UN-GHS labeling system is global law. It is, instead, a set of recommendations of best practice when it comes to safe chemical handling and no one is obligated to be a part of it. In the United States, the Occupational Safety and Health Administration (OSHA) incorporated these recommendations into regulations with safety in mind, and so far, over 65 countries are in the process of adopting GHS or already have adopted it. Before GHS guidelines, the way that each country managed their chemical handling was inconsistent and sometimes not safe, was confusing and was causing costly errors. Not only that, the risks presented to the workforce were so high that something had to be done.
The US OSHA put forward new compliance requirements designed to enhance and align the way that hazardous chemical information is communicated becoming the basis for the framework known as the UN Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. The regulations came into force in the US almost 4 years ago, on June 1, 2015. Chemical manufacturers, importers, distributors, and employers must now comply with the Hazard Communication (HazCom) label requirements when OSHA adopted the UN GHS in 2012. All containers with hazardous chemicals must include compliant GHS labels.
The Six Important Categories for GHS Label Compliance
- The chemical importer/manufacturer: Name, address and telephone number of the manufacturer of the chemicals, the importer or any other responsible party behind the sending of the item.
- A Chemical Name: The product identifier is essential, and the manufacturer of the chemicals must provide it. Each original container label must include chemical name, CAS number and code/batch number. The same identifier has to be on the label and in the safety data sheet under section 1.
- A Signal Word: These are words that are usually there to identify the severity of the hazard. “Danger” and “Warning” are the two signal words, and putting one on the shipment is required. For more severe hazards, “Danger” is the word that is necessary, whereas “Warning” is for hazards that are less severe. You must only use one word on the label, no matter how many hazards that the individual chemical may have.
- A GHS Pictogram: GHS pictograms are graphic symbols to communicate instant information about the hazards contained in that chemical. Manufacturers that are shipping hazardous chemicals must include GHS pictograms that are wide enough to be visible to the recipient. Red square frames should only be on the GHS label if it is a pictogram; otherwise, it should not be there as it can become confusing otherwise. GHS has nine pictograms, but OSHA only enforces eight of those allowing the environmental pictogram to be optional.
- A Hazard Statement: The nature of the hazards requires a description of the original chemical containers. There are hazardous chemicals that can damage skin and organs; these adverse effects must be included on the label. GHS labels need clarity, and hazard statements give that to the recipients.
The following is an example by OSHA’s hazard statement for acetic acid, CAS 64-19-7:
o Flammable liquid and vapor.
o Causes severe skin burns and eye damage.
- A Precautionary Statement: The precautionary statement is the description of measures that are recommended to prevent the effects of exposure to hazardous chemicals. There are four different types of precautionary statement, and these are:
A single GHS label can and does contain more than one statement, and they are allowed to be combined. The strictest statements are required to be on the GHS label when a chemical is classified as being hazardous.
Employer Responsibility & GHS Labels
It comes down to the employer to ensure that they see all six elements of the compliance list on any hazardous chemical containers that arrive at their workplace. Whether the label itself is on a tank, tote, drum, can or bottle, the employer is responsible for ensuring that they are effectively labeled and the integrity of those labels is maintained. They must be legible, and include the correct information, from the hazards in the chemicals to the directions for safe handling.
Employers are also responsible for ensuring that secondary containers are labeled. Often, certain operations require transferring chemicals from the original labeled container into a secondary container (e.g., a smaller container such as spray bottle, beaker, flask, or bottle). Portable containers must comply with the labeling requirements if any of the following events occur:
- The material is not used within the work shift of the individual who makes the transfer.
- The worker who made the transfer leaves the work area.
- The container is moved to another work area and is no longer in possession of the worker who filled the container.