GHS - OSHA HCS Comparison Comparison Of Hazard .

Comparison of Hazard Communication RequirementsPurposeComparisonThe purpose of the HCS and GHS are consistent. The HCS is one of the major existing systems which was to beharmonized by the GHS. While the intent of the GHS in international harmonization, it will also addressharmonization of sectors and regulations within countries.OSHA HCS 29CFR1910.12001GHS229 CFR 1910.1200 (a)(1) PurposeThe purpose of this section is to ensure that the hazards of allchemicals produced or imported are evaluated, and thatinformation concerning their hazards is transmitted toemployers and employees. This transmittal of information isto be accomplished by means of comprehensive hazardcommunication programs, which are to include containerlabeling and other forms of warning, material safety datasheets and employee training.(a)(2)This occupational safety and health standard is intended toaddress comprehensively the issue of evaluating the potentialhazards of chemicals, and communicating informationconcerning hazards and appropriate protective measures toemployees, and to preempt any legal requirements of a state,or political subdivision of a state, pertaining to this subject.Evaluating the potential hazards of chemicals, andcommunicating information concerning hazards andappropriate protective measures to employees, may include,for example, but is not limited to, provisions for: developingand maintaining a written hazard communication program forthe workplace, including lists of hazardous chemicals present;labeling of containers of chemicals in the workplace, as wellas of containers of chemicals being shipped to otherworkplaces; preparation and distribution of material safetydata sheets to employees and downstream employers; anddevelopment and implementation of employee trainingprograms regarding hazards of chemicals and protectivemeasures. Under section 18 of the Act, no state or politicalsubdivision of a state may adopt or enforce, through any courtor agency, any requirement relating to the issue addressed bythis Federal standard, except pursuant to a Federally-approvedstate plan.1.1.1 Purpose1.1.1.1. The use of chemical products to enhance andimprove life is a widespread practice worldwide. Butalongside the benefits of these products, there is also thepotential for adverse effects to people or the environment.As a result, a number of countries or organizations havedeveloped laws or regulations over the years that requireinformation to be prepared and transmitted to those usingchemicals, through labels or Safety Data Sheets (SDS).Given the large number of chemical products available,individual regulation of all of them is simply not possiblefor any entity. Provision of information gives those usingchemicals the identities and hazards of these chemicals, andallows the appropriate protective measures to beimplemented in the local use settings.I-21.1.1.2 While these existing laws or regulations are similarin many respects, their differences are significant enough toresult in different labels or SDS for the same product indifferent countries. Through variations in definitions ofhazards, a chemical may be considered flammable in onecountry, but not another. Or it may be considered to causecancer in one country, but not another. Decisions on whenor how to communicate hazards on a label or SDS thusvary around the world, and companies wishing to beinvolved in international trade must have large staffs ofexperts who can follow the changes in these laws andregulations and prepare different labels and SDS. Inaddition, given the complexity of developing andmaintaining a comprehensive system for classifying andlabelling chemicals, many countries have no system at all.1.1.1.3 Given the reality of the extensive global trade inchemicals, and the need to develop national programs toensure their safe use, transport, and disposal, it wasrecognised that an internationally-harmonized approach toclassification and labelling would provide the foundationfor such programs. Once countries have consistent andappropriate information on the chemicals they import orproduce in their own countries, the infrastructure to controlchemical exposures and protect people and the environmentcan be established in a comprehensive manner.

Comparison of Hazard Communication Requirements1.1.1.4 Thus the reasons for setting the objective ofharmonization were many. It is anticipated that, whenimplemented, the GHS will:(a) enhance the protection of human health and theenvironment by providing an internationallycomprehensible system for hazard communication;(b) provide a recognized framework for those countrieswithout an existing system;(c) reduce the need for testing and evaluation of chemicals;and(d) facilitate international trade in chemicals whose hazardshave been properly assessed and identified on aninternational basis.1.1.1.5 The work began with examination of existingsystems, and determination of the scope of the work. Whilemany countries had some requirements, the followingsystems were deemed to be the “major” existing systemsand were used as the primary basis for the elaboration ofthe GHS:Requirements of systems in the United States of Americafor the workplace, consumers and pesticides;(b) Requirements of Canada for the workplace, consumersand pesticides;(c) European Union directives for classification andlabelling of substances and preparations;(d) The United Nations Recommendations on theTransport of Dangerous Goods.1.1.1.6 The requirements of other countries were alsoexamined as the work developed, but the primary task wasto find ways to adopt the best aspects of these existingsystems and develop a harmonized approach. This workwas done based on agreed principles of harmonization thatwere adopted early in the process:(a) the level of protection offered to workers, consumers,the general public and the environment should not bereduced as a result of harmonizing the classification andlabelling systems;(b) the hazard classification process refers principally tothe hazards arising from the intrinsic properties of chemicalelements and compounds and mixtures thereof, whethernatural or synthetic;(c) harmonization means establishing a common andcoherent basis for chemical hazard classification andcommunication, from which the appropriate elementsrelevant to means of transport, consumer, worker andenvironment protection can be selected;(d) the scope of harmonization includes both hazardclassification criteria and hazard communication tools, e.g.labelling and chemical safety data sheets, taking intoaccount especially the four existing systems identified inthe ILO report;(e) changes in all these systems will be required to achievea single globally harmonized system; transitional measuresshould be included in the process of moving to the newsystem;I-3

Comparison of Hazard Communication Requirements(f) the involvement of concerned internationalorganizations of employers, workers, consumers, and otherrelevant organizations in the process of harmonizationshould be ensured;(g) the comprehension of chemical hazard information, bythe target audience, e.g. workers, consumers and thegeneral public should be addressed;(h)validated data already generated for the classification ofchemicals under the existing systems should be acceptedwhen reclassifying these chemicals under the harmonizedsystem;(i) a new harmonized classification system may requireadaptation of existing methods for testing of chemicals;(j) in relation to chemical hazard communication, the safetyand health of workers, consumers and the public in general,as well as the protection of the environment, should beensured while protecting confidential business information,as prescribed by the competent authorities.I-4

Comparison of Hazard Communication RequirementsScopeComparisonThe GHS scope clarification is consistent with the HCS exemptions and labeling exceptions. Consumer productsand pharmaceuticals are specifically addressed in the GHS scope. The HCS includes laboratories, sealedcontainers and distributors while as a framework for systems the GHS does not include these specific issues.The GHS addresses testing in the scope section. The HCS addresses testing under hazard determination. TheGHS and HCS do not require testing for health hazards. All the physical hazards in the HCS are not linked tospecific test methods (as is the case in the GHS) and testing for physical hazards is not required.OSHA HCS 29CFR1910.1200129 CFR 1910.1200 (b) Scope and application(b)(1)This section requires chemical manufacturers or importers toassess the hazards of chemicals which they produce or import,and all employers to provide information to their employeesabout the hazardous chemicals to which they are exposed, bymeans of a hazard communication program, labels and otherforms of warning, material safety data sheets, and informationand training. In addition, this section requires distributors totransmit the required information to employers. (Employerswho do not produce or import chemicals need only focus onthose parts of this rule that deal with establishing a workplaceprogram and communicating information to their workers.Appendix E of this section is a general guide for suchemployers to help them determine their complianceobligations under the rule.)GHS21.1.2 Scope1.1.2.1 The GHS includes the following elements:(a) harmonized criteria for classifying substances andmixtures according to their health, environmental andphysical hazards; and(b) harmonized hazard communication elements, includingrequirements for labelling and safety data sheets.1.1.2.2 This document describes the classification criteriaand the hazard communication elements by type of hazard(e.g. acute toxicity; flammability). In addition, decisionlogics for each hazard have been developed. Someexamples of classification of chemicals in the text, as wellas in Annex 7, illustrate how to apply the criteria. There isalso some discussion about issues that were raised duringthe development of the system where additional guidancewas thought to be necessary to implement the system.1.1.2.3 The scope of the GHS is based on the mandatefrom the 1992 United Nations Conference on Environmentand Development (UNCED)for development of such asystem as stated in paragraphs 26 and 27 of the Agenda 21,Chapt

(b) harmonized hazard communication elements, including requirements for labelling and safety data sheets. 1.1.2.2 This document describes the classification criteria and the hazard communication elements by type of hazard (e.g. acute toxicity; flammability). In addition, decision logics for each hazard have been developed. Some