- The classification of chemicals by type(s) of hazard(s) presented
- The harmonization (e.g. standardization) of hazard communication elements
- The provision of information regarding the physical hazards and toxicity of chemicals
The GHS is much like an NFPA standard, in that unless formally adopted in other binding regulations it is voluntary. For example, in the transportation of hazardous materials here in the U.S., the Department of Transportation aligned 49 CFR 100-185 (otherwise known as the Hazardous Materials Regulations or HMR) with the GHS in the 2007/2008 time frame so that compliance with the GHS in the transportation realm is mandatory. In the workplace, the Occupational Safety and Health Administration (OSHA) has aligned 29 CFR 1910.1200 (otherwise known as the Hazard Communication Standard (Haz Comm or HCS) with the third edition of the GHS. The revised HCS was effective May 25, 2012 and the utilization of the revised standard will become mandatory on June 1, 2015. Until the mandatory usage deadline, workplaces may use the former HCS, the revised HCS, or a combination of the two.
As hazardous materials/emergency responders (and as workers), we will see four major changes occurring commensurate with the implementation of the revised HCS and consequently the GHS, including the following:
- Revised hazard classifications of chemicals
- New requirements for the labeling of chemicals
- The transition of Material Safety Data Sheets (MSDSs) into Safety Data Sheets (SDSs)
- New requirements for information-sharing and training
With the advent of the GHS and revised HCS, chemicals are now classified within three hazard types-physical, health and environmental. Physical hazard categories can range from gases under pressure, to pyrophoric liquids, to organic peroxides — approximately 16 categories in all. Health hazard categories can range from acute toxicity, to carcinogenicity, to aspiration toxicity — approximately 10 total categories.
There are three environmental hazard categories, consisting of hazardous to the aquatic environment, acute aquatic toxicity, and chronic aquatic toxicity. Within the GHS, the description of the severity of each hazard category the chemical or product exhibits may be denoted with an alphabetical identifier in some categories and a numerical identifier in others. The numerical identifiers may be a source of confusion for emergency responders, as the GHS identifiers (1 denoting the greatest hazard and 5 the least hazard) is in polar opposition to that used in the more familiar HMIS label and NFPA 704 system identifiers (0 denoting the least hazard and 4 the greatest hazard). In case any responders are concerned about such a change in numerical hazard identifiers in the familiar HMIS and especially NFPA 704 systems, there is no immediate concern as no changes are projected and the NFPA is remaining steadfast on the need to preserve the current system due to the familiarity of the emergency response community with it.
The second major change inherent with the revised HCS/GHS is that of the labeling requirements for chemical containers. Compliant labels shall contain the following information:
- Symbols (hazard pictograms)
- Signal words (“Danger” [more severe] or “Warning” [less severe])
- Hazard Statements (e.g. “Causes Eye Irritation”, “Harmful If Inhaled”, etc.)
- Precautionary statements (related to prevention, response, storage, and disposal information)
- The product identifier used in the Safety Data Sheet
In addition, containers that are shipped shall contain the name, address, and telephone number of the manufacturer, importer, or responsible party. As an emergency responder, you may have already noticed the prevalence of revised HCS/GHS compliant labels in the field. If you have not, you will be encountering them soon.
When discussing the revised hazardous chemical package labeling requirements above, we touched on the symbols required (hazard pictograms on inner container labels and transport pictograms on outer container labels). While the transport pictograms resemble our current DOT labels, the hazard pictograms are an entirely new development. Hazard pictograms have been developed to denote the presence of specific physical, health, or environmental hazard categories presented by a chemical or product. Each pictogram lies within a red square-on-point border (per the GHS the border may be black if the chemical or product is not shipped internationally, however with the revised HCS the border is required to be red). As an example, a carcinogen, respiratory sensitizer, or chemical/product presenting aspiration toxicity would require the following pictogram on its label:
The next major change in what we will see not only in the field, but also in our workplaces lies in the transition of Material Safety Data Sheets (MSDSs) into Safety Data Sheets (SDSs). The new SDS format will consist of 16 specific sections and will also contain the relevant hazard pictogram or pictograms. There is nothing earth-shattering inherent with this transition, however emergency responders should be prepared to encounter the SDSs and personnel with occupational safety responsibilities should obtain all needed SDSs for the products/chemicals present in the workplace.
Did we just hear the cry of “What about container labels in our workplace?” Again, another feeble attempt at hazmat humor! In all seriousness, the current HMIS-type labels used on any container not possessing the required information (e.g. clear plastic spray bottles) are considered to be revised HCS/GHS compliant, however new GHMIS labels that replace the zero to four numerical ratings of product hazards with appropriate hazard pictograms that are either checked or the non-applicable pictograms darkened out on the label are available and can be used in lieu of the older type labels.
The final major changes inherent with the revised HCS/GHS lie in the information sharing with and training of employees. In terms of information sharing, all employees shall be informed of the requirements of the HCS, any operations in their work area where hazardous chemicals are present, and the location and availability of the written elements of the workplace Hazard Communication Program. In the training arena, employee training shall consist of the methods used to detect a hazardous chemical release in the workplace, the hazards of chemicals present in the work area, the measures for protection from any hazards, and the details of the workplace Hazard Communication Program.
And now to the big question — When does all this take effect and when is the deadline for employee training?
The answer is actually fairly simple (believe it or not!). By Dec. 1, 2013, all employees shall be trained in the labeling requirements and the format of SDSs. By June 1, 2015, all employers shall be compliant with the revised HCS and by Dec. 1, 2015 all shipping labels shall be revised HCS/GHS compliant.
In summation, the advent of the GHS and adoption of the components therein in the revised HCS will affect hazardous materials responders specifically and emergency responders in general in both response activities and in everyday station and work life. The GHS will actually enhance our safety through the clear conveyance of chemical hazard information and the standardization of same on a global level.
Be sure to visit the North Carolina Association of Hazardous Materials Responders website at www.nchazmat.com.
Glenn Clapp is Past President of the North Carolina Association of Hazardous Materials Responders and is a Fire Training Commander (Special Operations) for the High Point Fire Department. He is a Technician-Level Hazmat Instructor, a Law Enforcement Hazmat Instructor, and is a Certified Hazardous Materials Manager and Certified Fire Protection Specialist.