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GHS Update: Release of the Third Revised Edition and OSHA’s Proposed Rule Implementing the Globally Harmonized System of Classification and Labeling of Chemicals

Beveridge & Diamond, P.C., October 1, 2009

In July 2009, the Transport Division of the United Nations Economic Commission for Europe (“UNECE”) published the third revised edition of the Globally Harmonized System of Classification and Labeling of Chemicals (“GHS”), an internationally-harmonized approach for classifying, labeling, and communicating information on hazardous chemicals.  On September 30, 2009, the Occupational Safety and Health Administration (“OSHA”) published its proposed rule amending the hazard communication standard in order to implement the GHS third revised edition.

The GHS is a voluntary system designed to streamline the hazard assessment, labeling, and hazard communication requirements within and between countries by developing consistent criteria for classifying chemicals according to their health, physical, and environmental hazards, and creating labeling, safety data sheets (“SDSs”), and other communication based on those classifications.  Various national governments, U.S. federal agencies, regional institutions, and international organizations are in different stages of adopting and implementing the GHS.  To conform with the GHS, OSHA’s proposed rule modifies the existing hazard communication standard to include revised criteria for classification of chemical hazards, revised labeling provisions, and a specified format for SDSs.

The third edition reflects updates approved in December 2008.  It adds new provisions for the labeling of small packaging; two new sub-categories for respiratory and skin sensitization, revisions of the classification criteria for chronic toxicity to the aquatic environment, and a new hazard class for substances and mixtures hazardous to the ozone layer.

This GHS update reviews the historical background for the GHS, provides previews of its provisions, and reports on recent developments in the GHS and its implementation.  For the full report, please click here.

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