Do you know what the Globally Harmonized System is?
Well it seems not many people do. When we asked in our poll of April 19, 2013, “Do you know what the Globally Harmonized System (GHS) is?” Out of 221 respondents, 140 (63.35 percent) said no. The rest of the respondents either knew about GHS (59/26.70 percent) or were not sure (22/9.95 percent).
Since the publication of this poll commentary, Federal Regulations have come into force to update WHMIS 1998 to WHMIS 2015 which contains requirements for GHS and a transition period for implementation. Provincial and territorial
governments are also updating their Occupational Health and Safety law and Regulations to align with WHMIS 2015. These requirements and dates for transition period are not and will not be reflected in this article. Also, please note, not all employers have to
comply with WHMIS 2015 or provide training under WHMIS 2015. To find out if you must comply and what are the new requirements. Go to the Library section of the HRinfodesk website.
What is the Globally Harmonized System?
According to the Canadian Centre for Occupational Health and Safety:
"GHS stands for the Globally Harmonized System of Classification and Labelling of Chemicals. GHS is a system that defines and classifies the hazards of chemical products, and communicates health and safety information on labels and material safety data sheets (called Safety Data Sheets, or SDSs, in GHS)."
The GHS is an internationally agreed-upon system, created by the United Nations that sets universal rules for classifying hazards, and a universal format and content for labels and safety data sheets. The UN expects the system to be adopted and used around the world to make it easier for businesses and workers that handle hazardous materials to understand what they are handling, and to facilitate international trade in chemicals.
By the current standard, chemical manufacturers and importers convey hazard information on labels and safety data sheets in whatever format they chose. The GHS standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labelling products and preparing safety data sheets.
In Canada, the Workplace Hazardous Materials Information System (WHMIS) is the government's method of communicating safety and hazard information to citizens, specifically via labelling of controlled products, the presence of material safety data sheets and worker education and training programs. WHMIS and its associated legislation will require modification to align with the GHS.
According to the Canadian Centre for Occupational Health and Safety, "Health Canada has had an administrative policy to accept the GHS 16-heading Safety Data Sheet (SDS), as long as WHMIS content requirements are met."
Canada is phasing in the Globally Harmonized System of Classification and Labelling of Chemicals to update the current labelling system for safety data sheets under WHMIS. Federal legislation and regulations require adoption of the GHS by June 2015, and occupational health and safety legislation requires employers to train their workplaces on the GHS by June 2016.
In brief, the transition to the GHS in WHMIS will:
- Necessitate the modification of chemical and toxicological hazard classification criteria
- Require the use of signal words and changes to some symbols on the supplier label
- Require the use of a standardized 16-heading safety data sheet
- Eliminate barriers to international trade in chemicals for which hazards have been assessed against the GHS criteria
- Promote regulatory efficiency, facilitate compliance and provide better and more consistent information to stakeholders
Application of the GHS components may vary by type of product or stage of the life cycle. For example, where the product is intended for consumption as sold, pharmaceuticals, food additives and pesticide residues in food will not be subject to the GHS in terms of labelling. However, these types of chemicals would be covered in transport and the manufacturing process where workers may be exposed.
Criteria for classifying chemicals have been developed for the following health hazard classes:
- Acute toxicity
- Skin irritation/corrosion
- Serious eye damage/eye irritation
- Respiratory or skin sensitization
- Mutations in germ cells
- Reproductive toxicity
- Target organ systemic toxicity - single exposure
- Target organ systemic toxicity - repeated exposure
- Aspiration hazard
- Chemical mixtures
Criteria for classifying chemicals have been developed for the following physical hazard classes:
- Flammable liquids, solids, gases and aerosols
- Pyrophoric liquids and solids
- Self-heating substances
- Substances which, in contact with water, emit flammable gases
- Oxidizing liquids, solids and gases
- Organic peroxides
- Self-reactive substances
- Gases under pressure
- Explosive substances (liquid or solid) and explosive articles
- Corrosive to metals
Criteria for classifying chemicals have been developed for the following environmental hazard class:
- Hazardous to the aquatic environment
International GHS committees continue to develop additional hazard classes. Currently work is being done to establish criteria for the following classes:
- Hazardous to the terrestrial environment
- Chemicals which with contact with water give off toxic or corrosive gases
“WHMIS after GHS” will result in new:
- Classification rules and hazard classes
- Formats for Safety Data Sheets (formerly Material Safety Data Sheets)
- Label requirements
- Hazard symbols/pictograms
How should you prepare?
The US Occupational Safety & Health Administration (OSHA) has recently implemented the globally harmonized system. For the first time ever, OSHA labels will be required to show a pictogram to help convey hazard information.
In Canada, we are starting to see the GHS pictograms on safety data sheets and product labels. However, companies should not start classification or reclassification right away, but to get serious about learning the rules to GHS.
You need to be aware that:
- Hazard class names are changing
- Some products that were not controlled under WHMIS may now be controlled
- WHMIS after GHS will not be less protective
- Material Safety Data Sheets are changing to the new Safety Data Sheets (SDS)-16 headings, fixed order, new requirements (you cannot reshuffle old WHMIS data sheets to create new WHMIS after GHS-compliant SDSs)
- Suppliers must continue to provide SDSs to customers
- SDSs must continue to be available to all workers
- SDS updates are still required every three years, or when new information is available
- Confidential business information rules remain the same
Manufacturers, importers and distributors of hazardous chemicals should begin by learning the GHS criteria. For each product, they should:
- Identify the relevant hazard data for their ingredients
- Determine the appropriate hazard classes and categories
- Document the rationale and information for future reference
In the meantime:
- Suppliers can switch to a 16-section safety data sheet format provided it includes all of the information required on the current 9-section material safety data sheet
- Suppliers must continue to provide the current WHMIS classification and labels
Until the GHS is fully implemented, employers will need to educate staff on both the GHS and current WHMIS labelling. To help understand the new system, it is a good idea to request an updated 16-section safety data sheet for any product you purchase.
The three main tasks for most businesses are employee training, managing the safety data sheet and making sure the workplace labelling complies with GHS.
Employers are recommended to keep current inventories of all controlled products and simplify what is there by discarding those that are not in use. It will also be important to exercise patience during the transition period while companies attempt to transition to GHS compliant-labels.
Though it is still early, be on the lookout for upcoming guidelines and training requirements.
For more information on the GHS and WHMIS, visit www.whmis.gc.ca.