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Secondary Labeling (employer labeling)

OSHA's plans to bring greater global harmony to the Hazard Communication Standards (HCS) are not expected to drastically affect secondary labeling. The agency has been working to incorporate select GHS standards into the HCS for several years now. However, the details of the final proposal have not yet been made public and won't be finalized until sometime near the end of 2011.

OSHA originally expected to provide the public finalized changes to the HCS in August of 2011, but then delayed the release until September. The release date has now been delayed again. OSHA officials say most changes in the proposal are expected to impact chemical manufacturers.

Known as the Globally Harmonized System of Classification and Labeling, GHS was developed by the United Nations to help bring global uniformity to hazardous chemical identification. If OSHA adopts their proposed changes, chemical manufacturers would likely be required to reformat their Material Safety Data Sheets (MSDS) to conform with GHS.

  1. Identification of the substance or mixture and of the supplier
  2. Hazards identification
  3. Composition/information on ingredients Substance
  4. Mixture
  5. First aid measures
  6. Firefighting measures
  7. Accidental release measures
  8. Handling and storage
  9. Exposure controls/personal protection
  10. Physical and chemical properties
  11. Stability and reactivity
  12. Toxicological information
  13. Ecological information
  14. Transport information
  15. Regulatory information
  16. Other information

Currently, the HCS considers a chemical as either an explosive or a non-explosive. GHS expands explosives into seven categories. There are a number of other classification standards that chemical manufacturers will need to adapt their labeling and MSDS information to if the proposal passes.

Many chemical manufacturers are preparing for these changes by reformatting their MSDS information now to comply with GHS standards.

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