On Sept. 30 the U.S. Occupational Safety and Health Administration published a proposed new Globally Harmonized System of Classi?cation and Labeling of Chemicals, amending the standard for hazard communication thats been in place since 1985. Public comments on the proposal are due by year end.
Rich Kraska of Kraska Consultants, Bonita Springs, Fla., highlighted some of the major issues for the lubricants industry at the Independent Lubricant Manufacturers Association meeting in October. Everyone will have to review and change their product labels, Kraska said. Label rules will be signi?cantly revised, to follow ANSI standards, with mandatory symbols and pictographs.
Will there be suf?cient time to comply? The proposed effective date is three years from publication of a ?nal rule, said Kraska, but there is no extension for formulators or small businesses.
One win for the lubricants industry is OSHAs decision to delete references to any ACGIH or NTP ARC or other lists in the proposal. Rather, new hazard de?nitions will include severity tiers. The one-positive-test standard has also been dropped, Kraska noted. Weight-of-evidence and other approaches are allowed.
Expect no big changes to trade secret protections, but ingredient disclosures will likely increase. The mixture rule – important to blenders – is more complex and more closely aligned with European rules.
Industry chatter is that OSHA underestimated costs to small businesses, Kraska said. Its going to be dif?cult to write safety data sheets. Youll need GHS software. Lisa, Gloria and all our colleagues join me in wishing you a happy holiday season and a peaceful and prosperous new year.