Changes Are Coming to Hazard Communication
The new GHS hazard communication recommendations will impact manufacturers, distributors, and users of welding consumables Article prepared by the AWS Safety and Health Committee. Comments can be submitted to SHC Secretary Steve Hedrick (steveh@aws.org). Reprinted with permission: The Welding Journal This article discusses the basic provisions of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Hazard Communication System, how they differ from previous hazard communication requirements, and with a focus on the classification process, their likely impact upon the welding workplace. In July 2003, the GHS was endorsed by the United Nations (UN) Economic and Social Council. The GHS was drafted to address the need for a common framework for the technical classification and communication of chemical hazards. According to the UN, “It (GHS) aims at providing a basis for harmonization of rules and regulations on chemicals at a national, regional, and worldwide level, an important factor also for trade facilitation.” The GHS objective is to provide a universal systematic, empirical approach for physical, health, and environmental hazard classification of pure substances and mixtures. The hazard classification process is the foundation upon which this systematic prescriptive approach is built. Once a product’s hazards have been classified, these chemical property, regulatory or test data derived classifications then drive much of the required outputs on product Safety Data Sheets (SDS) and package/container warning labels. The GHS is not a regulation or a standard, but a set of international recommendations that a competent authority can adopt, in whole or in part, according to the “building-block” approach. The UN publishes the GHS guidelines on hazard classification criteria, standardized label elements, and SDS format in its publication known as the ‘Purple Book.’ The first edition of the Purple Book was approved by the Committee of Experts at its first session in December 2002. The GHS Purple Book is updated and revised every two years. The U.S. Adoption of GHS In March 2012, the United States Occupational Safety and Health Administration (OSHA) adopted the third revised edition of the GHS into its Revised Hazard Communication Standard. A majority of the new OSHA requirements take effect in June 2015, which corresponds to the European Union’s final deadline for incorporation of the GHS requirements for mixtures, following their previous adoption for pure substances. Many countries worldwide have similarly adopted GHS into their regulatory framework, or have plans to do so. The Key Principle of GHS Is Classification of Hazards Under GHS guidelines, hazard classification is specifically derived based on the intrinsic properties of a chemical substance or mixture. In other words, it is based upon the hazards the chemical substance or mixture exhibits in the form in which it is purchased, shipped, and received in commerce. This hazard classification does not include risks arising from subsequent use or transformation in the workplace. However, successful hazard communication includes information on the presence of potential end-use risks as well as the intrinsic hazards. Therefore, hazard communication information is still required in appropriate sections of a GHS formatted SDS or label to alert the user to minimize exposures and risks. Accordingly, by following established classification criteria under GHS, solid form welding consumable electrodes should be considered “Not classified as hazardous according to GHS,” due to their lack of intrinsic hazards. By definition, they are not considered exempt articles though, because they can present safety and health risks during their actual use in the workplace. For this reason, while they may not require the GHS label elements on product labeling, full GHS 16 Section formatted Safety Data Sheets are required for complete and proper hazard communication to end users of these products. Of course, packaging should continue to provide applicable warnings for physical hazards and health risks generated during the use of welding electrodes. Granular form welding products such as submerged arc flux are classified under GHS as they may present intrinsic hazards in the form they are sold, shipped, and received by the customer. They can become airborne as a dust, and the dust may contain hazardous constituents such as crystalline silica. Once properly classified according to GHS guidelines, they must have applicable compliant GHS labels on packaging as well as Safety Data Sheets authored and provided in accordance with competent authority requirements. The GHS Compliance Timeline In the United States, OSHA requires that all manufacturer/supplier’s SDS and product labeling conform to the GHS (Purple Book, Revision 3) requirements as of June 1, 2015. Distributors have until December 1, 2015, to ensure that all products sold conform to the new requirements. Canada has stated its intention to adopt GHS in alignment with the United States, but has yet to announce a date as to when GHS will be formally adopted into its existing WHMIS requirements. The European Union’s (EU) final implementation compliance date for SDS and label conformance coincides with OSHA’s June 2015 deadline. However, in the EU, there is still additional time allowed for distributors. China adopted GHS Purple Book, Revision 4 labeling and SDS requirements officially on May 1, 2011. How GHS Hazard Communication Is Different It’s true that data sheets and container/package warning labels have been around a good while as mandated by OSHA in the United States. Canada’s WHMIS includes similar hazard communication statutes, and so have most developed countries around the globe. The difference is that these pre-existing requirements were, by and large, performance based — whereas the new GHS requirements are principally prescriptive. In other words, before, it was up to the manufacturer to figure out what the hazards of their products were and to then develop Material Safety Data Sheets and container labels with whatever content they deemed necessary in order to adequately warn potential users in the workplace regarding their hazards and safe use of the products. Under GHS, manufacturers must first classify their products, be they considered substances or mixtures, according to their physical, health, and environmental hazards. (In the United States, OSHA does not specifically require provision of the environmental risk information as it doesn’t have jurisdiction over environmental matters.) This classification process follows according to specific empirically based criteria, and then from those prescribed classifications mandatory label and SDS text, warning statements, and warning symbol outputs are derived. Many of these classification guidelines rely on regional regulations, best practice standards, scientific chemical property data, published toxicological or ecological test data, and related published research studies. Therefore, manufacturers must obtain and compile this applicable published information by doing an extensive review of the literature, by subscribing to a service that provides this information, and/or by conducting their own scientific testing and research. In most cases, testing is not a requirement, as GHS established “Bridging Principles” that allow classification and hazard ratings to be calculated for mixtures based on the data available for its base level elemental or compound components. Figure 1 provides an example of how a label might look before and after GHS.
Figure 1
Figure 2
