The system – known as GHS – was adopted by the United Nations in 2003. The American Chemical Society said it strongly supports adoption of the system. Adoption of the GHS, as proposed by OSHA, promises improved protection of human health and the environment through warnings and precautionary language that are consistent across different products and materials as well as across all workplaces, the society stated. The proposed approach will address weaknesses or limitations in the current systems and will result in more effective warnings.

The chemical society noted that currently – depending on where the materials are used, manufactured or transported – each product or material may need to be classified by more than 15 different agencies and systems to comply with applicable regulations

The promise of the GHS, according to the society, is that a given material, regardless of the manufacturer or distributor, will have a similar classification, similar label language and similar precautions and work procedures outlined in the safety data sheets. This should result in the documents being easier to prepare and easier to understand.

The society pointed out there will still be significant hurdles to overcome to implement the new system. If adopted, there will be significant work for chemical producers and distributors to produce compliant warnings and significant training required for all chemical handlers to familiarize them with the new systems and associated warnings, pictograms, etc., the ACS stated.

The OSHA proposed regulations only apply to U.S. workplaces, the chemical society noted. Classification and labeling of materials for transport in the U.S. are already largely harmonized with international regulations, the ACS continued. Other areas, most significantly the harmonization of consumer product classification in the U.S., are not nearly as advanced. Therefore, adoption by OSHA of GHS may only be one step in a long process towards global harmonization of chemical hazard communication regulations, but it is a very important step.

According to the Independent Lubricant Manufacturers Association, all of its members are likely to be affected by the eventual changes to the Hazard Communication Standard. The associations Safety, Health, Environmental and Regulatory Affairs Committee is reviewing the proposal and plans to submit comments on behalf of ILMA.

Sasol Olefins and Surfactants official Thomas Grumbles spoke about the GHS at a metalworking fluids symposium sponsored by ILMA and others last October.

For the United States, its a move to a rules-based system from our previous appropriate hazard warnings, he explained. For the EU, it means new rules. For other areas of the world, its often the first-ever hazard communication system. So everybody has to change.

He noted that the new system will require new labeling with pictograms. In the EU, GHS is huge, Grumbles said. It will have a big impact worldwide on transportation regulations, storage and operational activities, workplace hazard communication, consumer products, pesticides, air quality and environmental risk.

Within Sasol, he continued, all Material Safety Data Sheets need to be revised, more products will be classified as hazardous, and the company will have more declarations as dangerous goods for transportation. Well need to apply more resources to reclassify and relabel, he added.

According to Grumbles, There will be a long period of disharmony, when we need to explain to workers and customers why products are reclassified and relabeled. Implementation will be difficult.

The proposed GHS may be viewed online at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=21110