MANAGING BEST PRACTICES: Ready for a new world order?
The effect of GHS efforts is most visible, at present, during the international transportation of hazardous materials. The Emergency Response Guidebook (ERG) developed jointly by Transportation Canada, the U.S. Department of Transportation, and the Secretariat of Transport and Communications of Mexico is an example of GHS. Global harmonization during hazmat transportation continues to evolve. For example, on January 8, 2003, the U.S. Hazardous Materials Regulations were amended to incorporate the most recent updates to the United Nations (UN) Recommendations on the Transport of Dangerous Goods.
Harmonization will impact all forms of chemical hazard communication including information provided to employees and consumers. Activity in this area will accelerate now that the United Nations officially adopted, in December 2002, a globally harmonized system for the classification and labeling of chemical hazards. This system is available for governments and organizations to implement now, although full implementation may take several years. The system may be viewed at http://www.unece.org/trans/danger/publi/ghs/officialtext.html. U.S. agencies that are examining how to incorporate GHS into regulations include OSHA and EPA.
Check the cardsEHS pros who wonder how harmonization might impact U.S. work sites should examine International Chemical Safety Cards (ICSCs). These cards are a harmonized system for hazard communication for pure substances on the "shop floor." They are a joint activity among the United Nations Environment Programme (UNEP), the International Labour Office (ILO), and the World Health Organization (WHO). ICSCs are available in numerous languages, even Swahili. About 1,300 cards have been completed and about 350 new ones are completed annually.
ICSCs are not legally binding documents and they do not replace a manufacturer's or distributor's unique material safety data sheet (MSDS). Headings of ICSCs, though, closely mirror headings of the International Council of Chemical Association's MSDSs. ICSCs are important because they use standard phrases, symbols/pictograms, and data to communicate chemical hazards.
Most importantly, development of ICSCs is transparent, including worker review, and ICSCs are verified and peer-reviewed by internationally recognized experts. In this respect, ICSCs are more accurate, reliable, and readable than most MSDSs. ICSCs have been available for several years through a subscription service. In June 2001, ICSCs became widely accessible and free over the Internet.
There are two English language versions of ICSCs: one published by WHO/EU and the other published by the National Institute for Occupational Safety and Health (NIOSH). The NIOSH version includes U.S. exposure limits but is otherwise identical to the WHO/EU version. NIOSH packages ICSCs with its "NIOSH Pocket Guide to Chemical Hazards and Other Databases" CD software (Publication No. 2002-140). The NIOSH version of ICSCs is available on the Web at http://www.cdc.gov/niosh/ipcs/icstart/html. ICSCs can also be found at OSHA's homepage on the Web (www.osha.gov) under the index for "hazard communications." At OSHA's hazard communications site you will also find OSHA's explanation for the globally harmonized system.
Communication concerns?On first blush, information in ICSCs should not pose a major dilemma for U.S. employers. Most chemical hazard/risk information in the U.S. is compatible with worldviews. An important exception, though, is treatment of reproductive hazards/risks.
U.S. employers generally avoid the term "unborn child" when addressing reproductive toxicity, preferring instead to use the term "embryo" or "fetus." This is likely due to political and legal concerns. It's rare to find "unborn child" on a U.S. manufacturer's or distributor's MSDS. But the term is a standardized Risk Phrase in EU safety data sheets and ICSCs.
EU Standard Risk Phrases for reproductive health include: (R60) May impair fertility; (R61) May cause harm to the unborn child; (R62) Possible risk of impaired fertility; (R63) Possible risk of harm to unborn child; and, (R64) May cause harm to breast-fed babies. Reproductive toxicity is further explained in the UN's new GHS.
U.S. employers are also cautious, again mostly due to political and legal reasons, about taking any actions that may be perceived to treat a pregnant employee differently than any other employee. But ICSCs shout out this difference. The wording in the ICSC exposure/prevention category for carbon monoxide (CO) - see box on right - is an example. Note the significance of capitalized words followed by an exclamation mark.
An even greater dilemma arises further down the ICSC for CO when the statement appears for pregnancy that "harmful effects are probable in spite of observance of MAK" at 30 parts per million (PPM). The MAK is an exposure limit used in Germany and several other countries. What implication does the MAK information have on observance of an OSHA permissible exposure limit at 50 PPM?
The data in an ICSC is hard to ignore because it is a highly credible source of hazard information. EHS pros can resolve the difference with one of three choices:
1) defer to regulatory requirements (if there are any);
2) defer to the most protective guideline; or,
3) explain risk decisions for the development of the guideline and permit management and employees to agree to which precaution will be followed.
How GHS might eventually impact workplace issues such as reproductive toxicity and other chemical hazard topics is unknown. But you should anticipate and prepare for the changes and challenges that will come.