| The Globally Harmonized System, or GHS, was | | | | largely unchanged. It will, however, need to be modified |
| proposed by the United Nations in an effort to | | | | to include any resulting changes to labeling and MSDS |
| internationally standardize classification and labeling of | | | | communication as well as related employee training. |
| chemicals and related hazard communication. Benefits | | | | |
| of the GHS include reduced time and costs involved in | | | | 7 Tips to Creating an Effective GHS Transition Plan |
| meeting multiple regulations for hazard communication, | | | | 1. Get Informed – learn all you can about the GHS |
| improved comprehension and understanding of health | | | | and be on the lookout for information related to the |
| and environmental hazards, facilitation of trade by | | | | new changes to best determine its potential impact on |
| removing barriers created by various health and | | | | your organization. Find a good resource for gathering |
| safety requirements, and reduction of duplicate testing. | | | | GHS-related information and check it often. The |
| The adoption of the GHS is a hot topic of discussion, | | | | website is an excellent source and also provides a |
| both domestically and internationally. While GHS has | | | | free newsletter, which will send timely news directly to |
| historically focused on the international community, with | | | | your inbox. |
| early adoption by the European Union and Japan, the | | | | 2. Timeframes - be sure you are aware of |
| GHS trend is moving west and is certain to affect U.S. | | | | implementation dates in your country as well as in the |
| companies in the near future, if not already. | | | | countries in which you do business (see the timeline on |
| GHS will have profound effects on chemical data | | | | the home page for information by country). Also, be |
| management initiatives, both for companies that must | | | | aware of the differences in adoption between |
| author and publish material safety data sheets (MSDS) | | | | countries as it may affect your exportation processes. |
| for their chemical products, as well as those | | | | 3. Don't Go It Alone - make sure your product and |
| companies that must manage MSDS and related | | | | service providers have a transition plan in place and |
| chemical data for onsite chemical inventories. | | | | are able to support you as you make the necessary |
| Specifically, the proposed regulatory updates will | | | | changes; this includes vendors who assist with: training, |
| require revisions in both content and format of current | | | | MSDS management, authoring new compliant |
| safety data sheets, thus causing an enormous amount | | | | documents, labeling, and transportation. Will they be |
| of work to create new content and manage new | | | | able to assist you as you transition to the GHS? Are |
| safety data sheets and labels for hazardous | | | | they informed about the GHS and will they be a useful |
| chemicals. | | | | resource for you? |
| However, the benefits are numerous for all parties | | | | 4. Vendor MSDS Management System – support |
| involved including chemical users, chemical producers | | | | your transition with a chemical information |
| and regulatory bodies throughout the world. The main | | | | management system that will aid in the administration |
| benefits to be realized via GHS are: | | | | of documents classified under existing and future |
| - Better employee protection due to consistent and | | | | regulations. Be sure your system is ready for the GHS |
| clear chemical hazard communication | | | | and is able to provide a consistent and clear message |
| - Compliance cost reduction for organizations covered | | | | to your employees, even in the event the MSDS does |
| by hazard communication standards | | | | not. How will you deal with vendors who are slow to |
| - More consistent and efficient regulatory oversight | | | | transition to the GHS and provide the updated MSDS |
| and standards | | | | requirements your employees need? Does your |
| - Reduction of international trade barriers | | | | MSDS management system provide a means for |
| | | | | tracking the new GHS classifications and pictograms? |
| GHS mostly affects companies that have to classify | | | | If your chemical vendors are slow to respond to the |
| hazards or prepare safety data sheets or workplace | | | | GHS, can your MSDS Management system offer |
| labels. Some of the more important changes include | | | | GHS classification guidance to assist with consistent |
| the following: | | | | messaging for your employees? |
| MSDS – the material safety data sheet will | | | | 5. Workplace Labels – workplace labels will need to |
| experience extensive change after adoption of the | | | | be updated to include the new pictograms and |
| GHS, as all products will need to be classified for | | | | statements. To ensure workplace safety and allow for |
| health and physical hazards based on GHS criteria. | | | | consistency, GHS labels may need to be created |
| The title of the document will also likely be changed to | | | | before an updated vendor MSDS is available. How will |
| Safety Data Sheet (SDS). Additionally, the flexibility | | | | you create such a label and classify it appropriately? |
| of format will be removed. The 16 section document | | | | Contact your labeling vendor to find out how they plan |
| (as adopted by ANSI Z400.1-2004) will be required and | | | | to assist you with compliance for the upcoming label |
| the order of the 16 sections will be specified; with | | | | changes. If your Vendor MSDS management program |
| section two being for hazard identification and section | | | | is able to track the new fields and classifications, can it |
| three being for components. The consistent format will | | | | also provide a GHS-compliant label? |
| greatly assist employees in quickly and easily finding | | | | 6. Product MSDS Authoring and Distribution – how |
| their information on the MSDS. | | | | will you reclassify your products according to the GHS |
| Labeling – the GHS will require standardization for all | | | | and how will that information be distributed to your |
| labels which will result in a reprocessing of every label | | | | customers? Be sure your authoring method will |
| during transition. Standardized pictograms, signal words, | | | | support GHS classification according to the various |
| hazard statements, and precautionary statements are | | | | countries' requirements, and that it will be able to |
| specifically designed to enhance communication for all | | | | create the necessary associated product labels and |
| those handling chemicals. These elements will also | | | | documents. You might consider adding an addendum |
| need to be placed on the label in specified locations. | | | | with the GHS classifications and related pictograms to |
| Hazard Classification – the current Hazard | | | | your existing product MSDSs during the interim period, |
| Communication Standard (HCS) is | | | | before full implementation is required. Explore your |
| performance-oriented such that the standard outlines | | | | options with respect to distribution; a validated |
| the expected outcome, but not the specific | | | | electronic distribution method could greatly assist in |
| implementation steps for hazard communication. | | | | allaying some of the costs associated with such a |
| GHS takes a much more detailed approach, specifying | | | | large project. |
| the detailed criteria and communication elements for | | | | 7. Training Program – training will be a key |
| each hazard class. | | | | component of your overall GHS approach and should |
| Training – educating employees on the label and | | | | incorporate information as it is introduced into the |
| MSDS changes due to the updated product | | | | workplace. Employees and emergency responders will |
| classifications, pictograms, signal words, and hazard | | | | need to be trained on all new elements they will be |
| and precautionary statements will represent the | | | | faced with, from hazard statements to pictograms. |
| greatest training challenge. From a process standpoint, | | | | Bear in mind, if products are imported from countries |
| training managers should plan to follow the existing | | | | that implement the GHS prior to the US, your |
| HAZCOM requirements, as the current training | | | | employee training may need to begin earlier than |
| procedures are more detailed than the GHS training | | | | expected. The sooner you begin planning your training |
| recommendations and will likely be retained. | | | | approach, the more likely you will achieve a successful |
| Written Program – because OSHA has indicated it | | | | transition. It is not too early to begin familiarizing your |
| will retain the provisions of HCS that are not affected | | | | employees with the upcoming pictograms and MSDS |
| by the GHS, the written program is expected to be | | | | format changes. |