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Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

Overview:

The Acta Group (Acta®) offers comprehensive global services in responding to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The manufacture, transport, labeling, and distribution of chemicals are a global business that must be managed correctly to avoid mishaps and ensure compliance. In 1992, the United Nations recognized, at the Rio Earth Summit, that developing the GHS on chemical classification, labeling, and handling of chemicals was the surest way to achieve international consistency on labeling and managing chemicals. The GHS is intended to standardize the criteria for classifying chemicals and hazard communication elements for material labeling and safety data sheets (SDS).

In the United States, the U.S. Occupational Safety and Health Administration (OSHA) issued a final rule aligning its Hazard Communication Standard (HCS) with the GHS in March 2012. OSHA's current HCS has been in place for three decades, since 1983. The rule became effective on May 25, 2012.

Major Changes to the Hazard Communication Standard

  • Hazard Classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
  • Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
  • SDSs: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
  • Information and Training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013, on the new label elements and SDS format, in addition to the current training requirements.

What You Need to Do and When:

  • Chemical Users: Continue to update SDSs when new ones become available, provide training on the new label elements, and update hazard communication programs if new hazards are identified.
  • Chemical Producers: Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and SDSs.
Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and SDS format. Employers
June 1, 2015*
 
December 1, 2015
Comply with all modified provisions of this final rule, except:
 
Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.
Chemical manufacturers, importers, distributors, and employers
June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers
Transition Period Comply with either 29 C.F.R. Section 1910.1200 (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors, and employers
*This date coincides with the European Union (EU) implementation date for classification of mixtures.

GHS Around the World:

Countries are adopting and revising GHS requirements at varying speeds and in differing ways. It is critically important for stakeholders in the chemical community to understand GHS, track its implementation, and adopt corporate GHS systems timely and well.

Our Experience:

Acta's global presence, with offices in North America, Europe, and Asia, is key to our ability to advise and guide clients on GHS issues in every territory.

Our North American team includes Lynn Bergeson, who counsels clients on issues pertaining to chemical hazard, exposure and risk assessment, and risk communication, with particular expertise in nanotechnology and other emerging technologies; Christopher Bryant, who delivers over 20 years of experience in environmental, health, and safety (EHS) compliance and regulatory issues; Karin Baron, M.S.P.H., who is skilled in the assessment and application of GHS globally, and certified in the transport of dangerous or hazardous goods; Leslie MacDougall, with more than 15 years of experience in international chemical control, including serving as U.S. Environmental Protection Agency’s (EPA) liaison to Organization for Economic Cooperation and Development (OECD) member country governments; Jane Vergnes, Ph.D., DABT® who provides toxicology support to the classification, labeling, and SDS preparation process based upon over 20 years of experience; Lara Hall, M.S., with ecotoxicology, environmental fate and physical chemical properties experience to offer in support of GHS compliance; and David Peveler, Ph.D., a chemist whose areas of specialization include GHS-CLP and Workplace Hazardous Materials Information System (WHMIS) compliant Safety Data Sheets (SDS) and labels.

Our EU-based professionals include Ruth Downes-Norriss, who provides expertise regarding supply chain and downstream user communication; and Gyöngyi (Pearl) Németh, M.Sc., who assists clients with comprehensive solutions for GHS compliance through classification and labeling direction, SDS preparation and review, and related training program design.

In Asia, Yang Ni and his team provide on-the-ground knowledge and assistance, and their longstanding relationships with regulatory agencies can be instrumental to clients' success throughout Asia.

What We Do:

Acta offers comprehensive global solutions for complying with GHS regulations:

  • Substance classification to conform with GHS;
  • SDS preparation and/or review to ensure compliance;
  • Label formulation for GHS compliance;
  • GHS training;
  • GHS program development and strategic consulting;
  • EU CLP Regulation services;
  • Hazard Communication (HazCom) services; and
  • OSHA HCS services.

Representative Engagements:

  • Provided GHS training for a Fortune 50 company;
  • Provided comprehensive webinar on GHS and HCS obligations for a major trade association;
  • Routinely provide strategic global counseling on rationalizing GHS obligations across jurisdictional boundaries for product lines and businesses; and
  • Assess and revise SDS for products marketed globally.

 
THE ACTA GROUP
Beijing, China | Manchester, U.K. | Washington, D.C.
 
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