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Cashins & Associates Blog

Global Harmonization System - 4 Changes Safety and Health Professionals Should know

Posted by Mike Cashins on Fri, Apr, 13, 2012 @ 11:04 AM

GHS_PictogramsThe GHS is an international approach to hazard communication, which provides criteria for the classification of chemical hazards and a standardized approach to label elements and Safety Data Sheets (SDS).  The GHS was negotiated over multiple years by Hazard Communications experts from different countries, international organizations, and stakeholder groups.  It is based on major existing systems around the world, including OSHA’s HCS.  OSHA’s HCS has adopted the GHS to help improve health and safety for American workers.  Some sections of the HCS are going to change and some sections are going to stay the same.


Four Major Changes to the HCS:

  1. Hazard Classification:  The revised HCS has specific criteria for each health and physical hazard, along with detailed instructions for hazard evaluation and determinations as to whether mixtures or substances are covered. It also establishes both hazard classes and hazard categories—for most of the effects; the classes are divided into categories that reflect the relative severity of the effect. OSHA has included the general provisions for hazard classification in paragraph (d) of the revised rule, and added extensive appendixes (Appendixes A and B) that address the criteria for each health or physical effect.
  2. Labels: The revised HCS has 4 specific details on what elements are now required on labels after the hazard classification has been complete.

    • Pictograms
    • Signal Words
    • Hazard Statement
    • Precautionary Statement
  3. Safety Data Sheets:  Material Safety Data Sheets (MSDS) terminology has now been changed to Safety Data Sheets (SDS).  The revised HCS will require the SDS to have a specific standardized 16 section format.
  4. Hazard Ranking System: A significant change which will impact worker training is that the numerical ranking order for hazard is reverse of the NFPA system. With the NFPA system hazard was ranked from 0 - 4; with a rating of 4 being high hazard. The GHS system has categories ranking in order of 1 - 5; with a rating of 5 being a low hazard. This may casue end user confusion until thorough training is provided. Training is one of the first requirements that comes into effect during the GHS Standard phase in.

There are major changes that Corporations, Safety Professionals, and Industrial Hygienists will need to make to their Hazard Communication Program. Due to this OSHA has provided a multi-step phase in schedule. Below is the table detailing when each phase of the standard is legally enforceable.

Cashins & Associates, Inc. is following this important standard carefully. We can assist you with implementing these new requirements to ensure your company is compliant. If you have any questions, we are here to help.    

Phase In Period for the revised HCS:


Effective Completion Date



December 1, 2013

Train employees on the new label elements and safety data sheet (SDS) format.


June 1, 2015*

December 1, 2015

Compliance with all modified provisions of this final rule, except:

The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label

Chemical manufacturers, importers, distributors and employers

June 1, 2016

Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.


Transition Period to the effective completion dates noted above

May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both

Chemical manufacturers, importers, distributors, and employers



Topics: health & safety, industrial hygiene, occupational health

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