The Occupational Safety and Health Administration (OSHA) published a notice of proposed rule making amendment for the Hazard Communication Program (1910.1200). The new amendment for the Hazard Communication Program is called the Globally Harmonized System (GHS) which will be in full effect by June 1, 2015.
One concern raised is how the GHS is going to impact the National Fire Protection Association (NFPA) 704, yellow, red, blue, and white Fire Diamond. This standard system is the current classification of ranking hazardous materials. The GHS will be new as of June 1, 2015, while NFPA 704 has been in use since the 1950s. Many industries and users of Material Safety Data Sheets (MSDS) have become familiar with the NFPA 704 Fire Diamond. There is discomfort among some emergency responders and workers who are familiar with NFPA system will be confused by the different numbering strategies of the GHS. NFPA and GHS hazard identification numbers are used to rank hazards based upon their seriousness. Those rankings occurring under GHS are called Hazard Categories, with five indicating the lowest hazard and one indicating the most severe. The NFPA on the other hand also uses numbers to indicate hazard severity only in their systems, the maximum number four represents the most severe hazard and zero representing no hazard. Below is a summarization of the change in the hazard ranking system.
- NFPA hazard ranking
- Ranked 0- 4; 4 being HIGH hazard.
- The new GHS hazard ranking
- Categories ranking in order of 1 – 5; 5 being a LOW hazard.
NFPA has expressed concern to OSHA by submitting the following:
NFPA made the following comments in December 2009:
“NFPA believes that the numbered hazard categories resulting from implementation of GHS will cause confusion among traditional users of the NFPA hazard rating and labeling systems. The NFPA 704 hazard rating system has been in effect since the 1950’s and has become a key element of MSDS information over the past 20 years.”
“Adoption of the NFPA 704 rating and labeling system through building or fire codes throughout the United States means that the recognized symbol and forms are prominently displayed and their posting is an important safety training topic for employers and employees. Additionally, the system is intended to advise the emergency responders in a readily recognizable manner of the immediate hazards associated with a facility.”
OSHA responded to this and other public comments regarding perceived confusion of the GHS by stating:
“OSHA recognizes that the approach to numbering hazard categories in the GHS differs from that used in the HMIS and NFPA systems. However, the Agency does not believe that this will result in confusion. GHS category\numbers determine the label elements that would be required for a chemical, but the category numbers themselves would not appear on labels. Where GHS category numbers would appear on the SDS (Section 2–Hazards identification), they would be accompanied by the label elements for the chemical, which would clearly indicate the degree of hazard. OSHA, therefore, does not anticipate that this information will cause employees to become confused. Moreover, the approach taken in the GHS (i.e., assigning higher category numbers to denote less serious hazards) is consistent with the approach used in the DOT transport regulations for many years.”
The ultimate users of MSDS are sure to encounter a massive overhaul of not only MSDS, which will be renamed to Safety Data Sheets (SDS) in the GHS rule, but training requirements, introduction of new required pictograms to indicate hazards and generally, as with all new regulations, some initial confusion. Typically, many are used to seeing the NFPA colored diamond on outside tanks of chemicals, buildings and it is commonly on the MSDS. Now, with OSHA's GHS numbering system, the chemical will have an altogether new numerical designation. Will this lead to confusion? Yes. Will training be required by employers? Yes. The OSHA GHS Standard requires that employees be trained in these changes by December 1, 2013. Training is required years before full implementation due to many European companies will have implemented the GHS system well ahead of the U.S. Regulation coming into effect. Industrial Hygiene and Safety Professionals will need to ensure that workers fully understand the difference between the two systems. This is especially critical during the transition to GHS as there will be crossover of the two systems until the law is fully enforced.
What is the future of NFPA Standard 704? At this point we have not heard any definitive information from the NFPA. The bottom line is, OSHA standards are the law. The NFPA 704 is a voluntary compliance system. Currently NFPA 704 has released its latest edition on August 31, 2011. The edition was developed during the crucial time when OSHA was announcing the changes in the Hazard Communication Program. We will have to wait and see how the overseers of the NFPA react once the GHS law is in effect.
If you would like assistance with the implementation of the GHS Standard at your facility we are here to help. Contact one of our Industrial Hygiene and Safety Professionals by submitting a question or request using our convenient web form.