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In December 2019, OSHA representatives traveled to Geneva, Switzerland, to participate in international meetings at the United Nations for the 38th session of the U.N. Sub-Committee of Experts on the Globally Harmonized System of Classification and Labeling of Chemicals (UNSCEGHS).

The Globally Harmonized System is called “GHS” for short and sometimes referred to as “the Purple Book.” GHS is a systematic approach for classifying chemical hazards and communicating health and safety information to employees.

In 2012, OSHA adopted elements of the GHS into the Hazard Communication Standard (HCS), 29 CFR 1910.1200. Revisions that affect U.S. facilities included: 

• adopting a new labeling system for chemicals in the workplace
• using a new, 16-section safety data sheet (SDS) format
• training employees on the new GHS HCS  

The final deadline for compliance with OSHA’s revised HCS was June 1, 2016.

What’s Next for U.S. Employers and GHS HazCom?

When OSHA adopted elements of the 3rd revised edition of GHS in 2012, employers in the U.S. were given a multi-year phase-in schedule to complete employee training and come into full compliance with the revised HCS.

As safety professionals adjusted to the GHS HazCom Standard here in the States, the international community forged ahead. The GHS is now in its 7th edition, and the time has come for OSHA to play catch-up with another harmonization rule. 

According to the Department of Labor’s most recent regulatory agenda, OSHA plans to propose a rule in January 2020 to again harmonize its HCS with the latest edition of the GHS. 

What Has Changed Since the 3rd Revised Edition of GHS?

The GHS has been revised a handful of times since OSHA adopted the 3rd revised edition in 2012. Changes in GHS editions 4 through 7 include but are not limited to:

• new hazard classifications for physical hazards, including chemically unstable gases, desensitized explosives, and non-flammable aerosols  
• new precautionary phrases for certain hazards
• updated hazard labels and label guidance
• updates to Safety Data Sheets
• a codification system for hazard pictograms
• revisions to the Flammable Gases hazard category

OSHA may not adopt all of the changes made to the GHS since 2012. GHS is an international model regulation, not an international law. Unlike an international law, which sets a uniform rule or rules for all countries to follow, the GHS model regulation allows each nation to adopt parts of the system and modify the rules to fit a country’s own needs.

For now, safety professionals and stakeholders should be aware that OSHA’s proposal to harmonize 29 CFR 1910.1200 with the latest edition of GHS is on the way in 2020 and that it will include at least some of the revisions made on the international level in the past 7 years. When OSHA releases the proposed rule to revise the HCS again, professionals responsible for employee safety and health should review the updates and identify any changes that impact their facilities’ hazard communication programs.

Until then, we wait.