What’s Happening with the Globally Harmonized System (GHS) in The United States?

By: Kirsten Alcock, Manager of Product Safety, email

A more recent update is now available. 

Last week at the Virtual Fall meeting for the Society for Chemical Hazard Communication (SCHC), representatives from Occupational Safety and Health Administration (OSHA) updated us on a variety of topics from what is going on with the Hazard Communication Standard (HCS), new Letters of Interpretation, and the Outcome of the GHS Sub-committee biennium. I’m going to focus on the GHS as many of us have been waiting for an update on the status.

Janet Carter of OSHA gave us a brief discussion on what the GHS is, what the OSHA rulemaking process entails, and where they currently stand. Most recently was the informal hearing with an additional comment period for those who were participating in the hearing. Currently, OSHA is analyzing the comments received during the rulemaking process and once they’ve gone through this process, they will then issue the final rule.

The purpose of the HCS rulemaking was to improve and enhance worker protection through clarifications of existing regulatory requirements, incorporation of new hazard classes & categories, to improve and streamline precautionary statements as well as facilitate international trade through increased alignment with other countries and other US agencies.

There will be changes to Appendix A through D with modifications including but not limited to changes in health hazard definitions, expanding and adding new hazard categories for physical hazards, new label element requirements, and updates to the Safety Data Sheets (SDS) in sections 9 and 11.

The OSHA informal hearing was September 21 – 23, 2021. OSHA received 33 requests of notice to appear (NOITA). 28 organizations or individuals presented comments at the hearing.
OSHA received more than 115 comments from individuals and organizations with most of the comments pertaining to small packages, concentration ranges, normal conditions of use, shipment dates, etc.

We are all hoping to see the final rule soon so we all start the process of moving from GHS Version 3 to 7 within the United States.

We will keep you all updated as news becomes available but for now it is business as usual.

Contact:
Dell Tech
Kirsten Alcock, B.Sc. (Hons) 
Manager, Product Safety Group
519-858-5074
kirsten@delltech.com


Dell Tech has provided professional, confidential consulting services to the chemical specialty

industry in Canada, the USA, Europe, and Asia for the last 40 years.

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