On 26 March 2012 the revised Hazard Communication Standard (HCS) was published in the Federal Register, to be effective on 25 May 2012 and become mandatory on 1 June 2015. This phase-in period is to give industry enough time to produce labels and Safety Data Sheets (SDS) consistent with the revised provision, During this period employers will be allowed to use at their own discretion, the existing HCS, the revised one, or both. Additional information and guidance is available at OSHA’s website.
This brings the US roughly in line with Europe. There the implementation of GHS is called Classification Labeling and Packaging – CLP. This introduces the United Nations globally harmonized system (UN GHS) for classification and labeling of chemicals into Europe. Thus CLP compliant labels are identical to GHS labels in EU and also apply to countries that have implemented GHS (though slight difference exists).
GHS pictograms can be viewed here: http://www.unece.org/trans/danger/publi/ghs/pictograms.html
What does this mean for Canada?
WHMIS: (TDG will be discussed in a subsequent Blog)
Here we have a well-established identification protocol and training methodology for employers and employees called Workplace Hazardous Materials Information System (WHMIS). This is not currently affected by the GHS and training of employees must continue for the time being; either WHMIS online training, WHMIS on-site Training or WHMIS Train-the-Trainer. However this may not continue very long. Health Canada has taken the lead with help from Transport Canada and Environment Canada to work on plans to implement GHS at home. They have been doing so for years but now the US has adopted GHS we should expect Canada to follow soon.
WHMIS will need to change to reflect the new GHS hazard classification criteria and communication rules, which means changes to the WHMIS labeling and Material Safety Data Sheet (MSDS) requirements. By the way under GHS nomenclature an MSDS will become a Safety Data Sheet (SDS). And, despite the overlap, there are some key differences between the two systems. For example:
1. Five more Hazard Classes than WHMIS:
2. Flammable gases
3. Flammable aerosols
4. Flammable liquids
5. Flammable solids
6. Oxidizing gases
7. Oxidizing liquids
8. Oxidizing solids
9. Self-reactive substances and mixtures
10. Pyrophoric liquids
11. Pyrophoric solids
12. Self-heating substances and mixtures
13. Organic peroxides
14. Corrosive to metals
15. Gases under pressure
16. Substances and mixtures which in contact with water, emit flammable gases
1. Identification 2. Hazard(s) identification
3. Composition/information on ingredients 4. First-aid measures
5. Fire-fighting measures 6. Accidental release measures
7. Handling and storage 8. Exposure controls/personal protection
9. Physical and chemical properties 10. Stability and reactivity
1. Toxicological information 12. Ecological information
13. Disposal considerations 14. Transport information
15. Regulatory information 16. Other information
Clearly all the above will require a massive reeducation of employers and employees across the country. As soon as there is an announcement from Health Canada of their schedule for implementation of GHS we will provide on-line classes in both WHMIS and Transportation of Dangerous Goods (TDG) to reflect the changes.