Can you tell me about the pending OSHA requirement for GHS MSDSs and whether Chemwatch is prepared for it?
February 24, 2012
Click here to view the most recent publication by the Office of Information and Regulatory Affairs regarding GHS regulation.
February 9, 2012
First a little background: GHS stands for the Globally Harmonized system of Classification and Labeling. Most countries of the world have some type of hazard communication law that requires the development and use of MSDSs and labels to communicate chemical hazards to workers. While all well intentioned, the diverse and sometimes conflicting international requirements have created confusion among those using the documents and challenges to the chemical manufacturers who are trying to comply with multiple laws. To address this problem, in 2003, the United Nations adopted a single system (GHS) and left it to individual countries to adopt it into their regulatory systems.
Many countries require compliance with GHS now (Japan and New Zealand for example), many more are in various phases of implementation. The United States Department of Labor (OSHA), in an effort to begin the implementation of GHS, issued a Notice of Proposed Rulemaking in November of 2009. They then began the process of holding public hearings to gather information from the stakeholders. When this was completed they issued a notice that they intended to publish a final rule in August of 2011 that included a ‘timetable’ for GHS implementation by US companies.
Many MSDS vendors implied this final rule date was a deadline set by OSHA to require GHS MSDSs and labels for US companies. This was never OSHA’s intent. The final rule was only to describe what was being done, why and a timetable for implementation.
In fact the final rule was not published in August 2011 and OSHA is still taking comments. As of February 2012, they have still not reissued a final rule date and when I spoke to OSHA they said it would be in 2012. The important thing to remember is that even when it is published there will be a reasonable timetable to allow the many companies who manufacture and import MSDS into the United States to modify their systems to produce GHS compliant documents. These will then filter down to your companies.
What are Chemwatch’s current capabilities for GHS? Chemwatch authors many MSDSs for companies around the world and we have been producing GHS compliant MSDSs in many languages for the past several years. Countries like Japan and New Zealand require it and many others, although still on an implementation timetable, accept them.
Every Chemwatch Gold MSDS is now available in a GHS version. If you are a current user of Chemwatch, you can find this by going to the options tab above the MSDS and select GHS instead of Local Version. See the GHS compliant MSDS below. You can see the GHS Classification, phrases and pictograms included. The rules for labeling and transportation are also somewhat different.
View a Chemwatch Gold MSDS in GHS Format
Some suppliers are now producing GHS MSDSs and we add them to Chemwatch when we get them. You can always identify a GHS MSDS by the presence of the Pictograms shown here (http://www.osha.gov/dsg/hazcom/ghs.html) section 4.3.1.