A major change that will dramatically affect the
MSDS and product labeling landscape is the
promulgation of the Globally Harmonized
System (GHS) by the United Nations. The
unavoidable challenges related to this and the recommended
worldwide implementation has created
significant interest, as well as apprehension, in the
world of environmental health and safety.
Change often brings anxiety, but with thoughtful
preparation, the proposed benefits can make a
significant difference in the effectiveness of MSDSs
as well as product labeling both domestically and
internationally. These benefits include greater consistency
with a clear message across sectors through
harmonization of signal words, pictograms and
hazard warnings; better workplace protection; and
the reduction of costs associated with preparation of
labels and (material) safety data sheets by classifying
chemicals once, for all agencies. Internationally,
GHS will enhance protection of people and the environment,
facilitate international trade in chemicals,
reduce the need for duplicate testing and evaluation,
and assist countries and international organizations
in the sound management of chemicals.
Change is coming
Although it appears not all countries agree completely
on how GHS should be applied, most have
come to agree on a few specific areas related to
MSDSs and labels. First, you can anticipate that
the MSDS will experience extensive change after
adoption of the GHS, as all products will need to
be classified for health and physical hazards based
on GHS criteria. The title of the document will
also likely be changed to Safety Data Sheet (SDS).
Additionally, the flexibility of format will be
removed. Specifically, the 16-section document
(as adopted by ANSI Z400.1-2004) will be required.
The order of the 16 sections will be specified; with
Section Two prescribed for hazard identification and
Section Three defined for components. The consistent
format will greatly assist employees in quickly and
easily finding pertinent information on the MSDS.
Labeling will also change quite significantly. The
GHS will require standardization of labels, which will
result in a reprocessing of every label during transition.
Standardized pictograms, signal words, hazard
statements and precautionary statements are specifically
designed to enhance communication for all
those handling chemicals. It appears that each region
and/or country may adopt different variations of the
GHS as it applies to hazard classification categories,
precautionary measures and hazard statements.
GHS and my workspace
How will this affect you? Some questions to
- Should I classify my product MSDSs across all
GHS hazard classification categories and adopt multiple
outputs to fit the requirements of each region or country
where my company currently distributes its products?
- Alternatively, should I prepare a globally compliant
document in order to increase my ROI and minimize the
expense of managing multiple MSDS and label formats?
- When (and how) will I transition completely to
the GHS format?
- How can I cost effectively rewrite, reclassify and
redistribute all of my MSDSs?
In order to select your best transition path, it is
critical that you and your company be well informed.
Understand the implementation timelines of the
countries where your organization conducts business.
OSHA estimates that in the U.S. alone, over 7 million
workplaces and 945,000 hazardous chemical products
will be affected by the GHS. While timing of the
GHS implementation standards is not yet defined, the
changes will undoubtedly be far-reaching. Because
Japan, Australia and Europe have already implemented
the GHS into their regulatory frameworks, your
employees could potentially receive an SDS in the
new GHS format in the near future. Not only that, but
you may be required to create a GHS-compliant SDS
if you do business in those countries.
Due to this reality, it is important that your MSDS service
providers have a system capable of meeting these
GHS requirements. Ensure that your service providers
have a system in place to be able to update your MSDSs
to include the new format, hazard classifications with
their corresponding hazard statements, precautionary
statements and pictograms. Beyond that, confirm that
your providers are able to update your workplace labels
to be GHS compliant when the time comes.
Finally, don’t forget your employees. Training must be
conducted to educate them about the new GHS information.
This is especially important if your organization
receives products from those countries that have implemented
the GHS prior to U.S. implementation.
Creating a GHS transition plan
How you address and prioritize your transition path
will have major implications to your business. Create
a GHS Transition Plan that considers these guidelines
for a smooth successful program:
- Embrace early adoption in order to establish
market differentiation and effectively serve your
- Identify service partners who have a deep
understanding of the EHS industry and issues and
provide a holistic service solution, not just a technology
- Conduct an ROI analysis to compare the
costs and benefits of an in-house vs. outsourced
GHS transition approach.
Following a sound GHS Transition Plan that incorporates
people, process and technology will allow your
organization to take advantage of the new GHS standards
by providing chemical management efficiency,
reducing plant and corporate risk and generating real
ROI in your chemical data management program.