How to Avoid the GHS Tidal Wave

Businesses need to execute their compliance initiatives now to prepare for the changing chemical requirements in the near-future


Chemical safety touches us all. It impacts the food we eat, our health and our lifestyle. Impediments to safety can endanger individuals, businesses and society in general. Common sense dictates that sound chemical management should rely on a single classification and labeling system to address specific use patterns and groups of chemicals at the national, regional and international levels.

Such a need especially rings true when you consider that some of the world’s largest economies produce more than $2 trillion while many fair-size countries’ economies produce less, which helps put in perspective the impact of the global chemical business. According to the Occupational Safety & Health Administration (OSHA), chemicals are an enterprise that generate more than $1.7 trillion per year. In the U.S., chemicals are more than a $450 billion business and exports are greater than $80 billion per year.

As such, companies urgently need to execute their compliance initiatives, especially since some of those that have begun the transition compare it to withstanding a tidal wave. By December 1, 2013, employers are required to train employees on the new label elements and Safety Data Sheet (SDS) format. As of June 1, 2015, chemical manufacturers, importers and employers are required to comply with all modified provisions of the final rule—distributors may ship products labeled by manufacturers under the old system until December 1, 2015.

If the appropriate tools and methods are in place to ride the wave, the volume and scope of change ahead will not be as daunting. But noncompliance with those initiatives carries a tremendous amount of risk throughout the supply chain. Upstream, noncompliance could result in significant fines and penalties and damage to the company’s reputation. Downstream, noncompliance may directly impact safety in the workplace. Conversely, compliant companies may realize reduced risk as a result of proper training and education of employees on the various aspects of the new standard.

Adoption across the masses

The need for a single chemical classification system was the impetus behind the creation of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), an international mandate adopted at the 1992 United Nations Conference on Environment and Development (UNCED), also known as the “Earth Summit.”

OSHA published its revised Hazard Communication Standard, known as HazComm 2012, in the Federal Register on March 26, 2012, aligning the standard with GHS. The standard has profound implications for supply chain professionals and requires extensive planning and preparation.

But the U.S. was not an early adopter of GHS. New Zealand led the way in 2001 and was quickly followed by a wave of Asia-Pacific nations. The European Union adopted the Classification, Labeling and Packaging (CLP), its version of GHS, along with the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation in 2009. Many countries have pending revisions under current consideration, while other nations require legislative action to enact such sweeping reforms. The varying implementation timetables for GHS across the world point to the need for supply chain professionals to assess their global supply chain operations and take into account GHS implementation timing in countries where they have operations or conduct business.

As much as GHS is meant to drive global harmonization, its various implementations lack consistency as individual countries are allowed to select the physical hazards; health and environment classes; and associated categories within each class they wish to adopt. Most countries that did implement GHS chose to keep some of their existing hazard classifications and communication standards that are not part of GHS. As a result, there is less harmonization among countries than originally anticipated.

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