In an effort to improve the quality and consistency of chemical hazard information provided to U.S. employers and employees, OSHA is proposing to modify its own Hazard Communications Standards (HCS) with several elements of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
Agency officials say incorporating some elements of GHS into OSHA HCS will enhance its effectiveness and help ensure, "employees are apprised of the chemical hazards to which they may be exposed, and in reducing the incidence of chemical-related occupational illnesses and injuries." Officials add it would also, "facilitate international trade, increasing competition, increasing export opportunities for U.S. businesses, reducing costs for imported products and generally expanding the selection of chemicals and products available to U.S. businesses and consumers."
OSHA's proposal to accept GHS standards is far reaching, but limited in scope. Many of the changes are revised GHS standards. OSHA believes these revisions are better suited to U.S. classification of: chemical hazards, labeling provisions that include requirements for use of standardized signal words, pictograms, hazard statements and precautionary statements.
As part of its proposal, OSHA would adopt all GHS physical and health hazard classes. The exception would be Acute Toxicity Category 5 for oral, dermal, or inhalation exposures; Skin Corrosion/Irritation Category 3; and Aspiration Hazard Category.
Countries have been encouraged to implement the GHS as soon as possible, and established a goal to have fully operational systems by 2008.
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GHS stands for Globally Harmonized System of Classification and Labeling of Chemicals. Development of the system was started in 1992 by the United Nations (UN). The goal was to provide uniform design standards for hazardous labels and signs throughout the world. All nations have been asked to participate, on a volunteer basis, with GHS. Since its start, participation has steadily grown in industrialized nations and now in developing countries as well.
GHS uses up to four diamond-based symbols to identify chemical hazards stored in containers. Each diamond is used to display a GHS symbol to identify a hazard type. Common hazard symbols include: flammable, explosive, gas, corrosive, poison and danger.
OSHA's proposed modifications to GHS adoption excludes the explosive symbol.
The GHS is an internationally harmonized system for classifying chemical hazards and developing labels and safety data sheets. However, OSHA believes the GHS is not a model standard that can be adopted verbatim. Rather, it is a set of criteria and provisions that regulatory authorities can incorporate into existing systems, or use to develop a new system. Flexibility and self-classification reduce administrative burdens and accommodate special requirements.
Whenever a chemical is transferred from its original container to another container, the container you transfer it into is called a "secondary container."
There are few cases where secondary containers do not require labeling. If you are unsure, the best solution is to label it.
Exception example: If the container is portable and will be used immediately by the person who transferred the chemical into that container, labeling is not required.
OSHA requires the label display the PRODUCT NAME, the HAZARDOUS CHEMICAL and words or safety symbols displaying the KEY HAZARDS (e.g. inhalation hazard, ingestion hazard, skin absorption hazard, skin irritant, eye corrosion hazard, etc). This information can be found on the chemical's original container, or on the MSDS. OSHA 29 CFR 1910.1200(f) describes secondary container rules in greater detail.
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