When OSHA revised the Hazard Communication Standard to align with the United Nation's model HazCom system called the Globally Harmonized System of Classification and Labelling of Hazardous Chemicals (GHS) in 2012, it set forth a series of phased-in compliance deadlines. This year, over a span of just six months, two of its four phased-in GHS deadlines will go into effect.
By adopting GHS, countries and agencies gain a universal playbook for classifying chemical hazards, authoring SDSs and labeling chemicals. The ultimate goal is to break down barriers to international trade, save manufacturers from having to create multiple disparate documents and labels, and provide employees with consistent hazard information on labels and across products and across manufacturers. This is not to say that every country that adopts GHS does so in the same way.
The United Nations encourages adopting countries to pick and choose which elements of the system it will incorporate into its existing chemical regulations. (This is referred to as the ‘Building Block Approach.’)1 Obviously, this approach does not result identical adoption and regulations by all countries. However, the flexibility does drive greater participation than could likely be achieved by stricter adoption requirements — as evidenced by the over 65 countries have already adopted or are in the process of adopting GHS.
In the United States, many covered employers are still struggling to satisfy requirements of OSHA's first GHS deadline, which went into effect on December 1, 2013. This was the date by which all employers were to have completed employee training on the new GHS label elements for shipped containers, and the updated safety data sheet format. 2 There were 6,148 HazCom violations issued by OSHA in FY 2014, making it OSHA's 2nd most frequently cited standard. Of those HazCom citations, 3,282 qualified as "serious" violations, classified by OSHA as involving a high probability of death or physical harm to workers. The five most-cited forms of HazCom violations3 were:
