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MANAGING BEST PRACTICES: Global harmonization headaches

October 2, 2006
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According to OSHA administrator, Edwin Foulke Jr., OSHA’s current “big issues” are: #1 hexchrome, #2 pandemic flu preparedness, #3 global harmonization, and #4 permissible exposure limits (PELs). Among these big issues, global harmonization is likely to become the biggest problem for most employers. Here’s why:

The only real argument on hexchrome is what the permissible exposure limit will be once all the lawsuits are finally settled. It’s unlikely OSHA will issue anything more than guidelines for pandemic flu preparedness. And we shouldn’t expect much from OSHA on updating PELs. It takes the agency more than a decade to update a PEL for just one chemical — hexchrome for example. Updating PELs as a group? Not likely.

Moving forward

Global harmonization, though, has a head of steam. As most EHS pros know, global harmonization refers to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). In 1992, an international mandate to develop a globally harmonized system for hazard classification and labeling was adopted at the United Nations. OSHA cannot drag its feet on GHS. The agency must keep pace with activities of other countries, particularly in Europe, as well as with other U.S. agencies such as the EPA, DOT and FDA. All are pursuing GHS with their own standards. On the global front, GHS is methodically moving forward.

When OSHA says its working on global harmonization, it actually means staffers are looking at how the agency’s hazard communication standard will change. This is where big problems could arise. Hazcom impacts more employers than any other OSHA standard. And hazcom has been the most often cited “serious” general industry violation for the past several years.

Most frequently cited sections have been: 29 CFR 1910.1200 (e)(1) written hazard communication program; (h)(1) employee information and training; (g)(1) material safety data sheets; and (f)(5) container labeling. The standardized and specific nature of GHS has the potential to improve compliance (take out the guesswork) with some of these hazcom sections. But at least initially, employee training will become more challenging.

Upcoming OSHA action

OSHA’s Advanced Notice of Proposed Rulemaking (ANPR) for global harmonization was published on September 12th of this year. OSHA stated that the U.S. must move forward with other countries in the world to adopt GHS, both for economic necessity as well as to protect employees and the public from chemical hazards. For many more details, go to: http://www.osha.gov/dsg/hazcom/GHSOSHAComparison.html. OSHA’s site compares and explains OSHA’s hazcom requirements and GHS. OSHA’s ANPR for global harmonization cites this information. The comments OSHA is seeking in the ANPR cover almost a score of topics, including the time and cost to employers for modifying data sheets, how much new information to include on data sheets, and the timing for implementing these changes.

As you review comparisons between OSHA’s hazcom and GHS, be alert that many aspects of GHS are common in Europe. OSHA’s hazcom will become more like European versions of the standard, not vice versa.

Changes to come

Changes to the hazcom standard are almost certain:

1) Requirements for a specific 16-section material safety data sheet (called “safety data sheet” in the GHS) and pictograms on labels are examples.

2) Some definitions are certain to change, particularly definitions that categorize hazards, such as acute toxicity, skin corrosion and flammability.

3) GHS is not intended to harmonize risk assessment procedures or risk management decisions around the world. Still, you should be aware that GHS is harmonizing risk assessment definitions through agreement by experts. An example of harmonized definitions can be found by linking to http://www.who.int/ipcs/methods/harmonization/areas/ipcsterminologyparts1and2.pdf#search=%22IPCS%20risk%20assessment%20terminology%22 or found by conducting an Internet search for the document “IPCS Risk Assessment Terminology” Harmonization Project Document No. 1 by the World Health Organization (2004). You should begin including these harmonized definitions into your vocabulary now.

4) Pay particular attention to whether cut-off percentages for reproductive toxicity and category 1 mutagenicity (see definitions in the comparison document) make it into OSHA’s hazcom at 0.1 percent. Currently, the hazcom standard only requires carcinogens to be reported at 0.1 percent or greater. All other hazards must be reported on an MSDS at one percent or greater. Lower thresholds for reporting reproductive and mutagen hazards would be a significant change, especially when we look at how GHS warns of these hazards. See GHS label for “ZZZ Red Paint” in the comparison document as an example.

5) GHS calls for a special hazard category — “effects on or via lactation” — substances which cause concern for the health of breast-fed children. OSHA’s hazcom currently does not address this issue. If it’s changed, most U.S. safety and health pros will be faced with a new and significant challenge.

6) GHS influence will require revisions to almost every employer’s written OSHA hazcom program. There doesn’t seem to be any hope that GHS would eliminate the requirement.

Failure to have a written program is by far the most often cited violation of the hazcom standard, out-distancing other sections by more than two to one. The question is, “Why don’t many employers have a written program?” Fill-in-the-blank templates for a written hazcom program have always been readily available and free, in most cases. In late October 2005, NIOSH created a free downloadable or CD-ordered version of “HazCom Helper” software (see http://www.cdc.gov/niosh/mining/products/product44.htm) that helps employers write a hazcom program.

Bottom line

OSHA’s hazcom standard has been in effect for more than 20 years and is about to undergo a significant change. You should be aware that the change will be more than just cosmetic — and your management needs to know this, too. This will be an occasion to remind businesses that more than hazard communication is necessary to effectively address chemical risk. Are you confident in your strategies for chemical risk assessment, risk management and risk communication?

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