Hazard Communication Standard (HCS)
New changes to the OSHA HCS is bringing united states into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals(GHS). GHS is an internationally agreed upon standard managed by the united nations. Chemical manufacturers and importers are required to evaluate the hazards of the chemicals. In the united states they are required to produce labels, safety data sheets (SDS) to convey the hazard information downstream. According to European chemicals agency (ECHA) Down Stream users are “Companies or individual workers who use chemicals, this includes companies who manufacture goods or offer services where chemicals are not the main element of their business, such as food, construction or cleaning companies.” All employees who handle/use hazardous chemicals in the United States must have the labels and safety data sheets with addition training in handling procedures to ensure safe use. The biggest changes to this alignment is with the hazard classification system, labels, SDS, Information and training. The hazard classifications have specific criteria for classification. Labels will contain harmonized signal words, pictograms, and hazard statements. The SDS will be in the 16-section format. All employers are required to train workers on label elements and SDS.
The European Union has implements the GHS system with integration of their Classification and Labelling (CLP) system as well. This system encompasses hazard identification and classification, labelling, packaging, and poison centers. Poison centers is a must as the European Commission states,
“EU countries are required to set up appointed bodies (often known as poison centers) for receiving information on the composition of hazardous mixtures (detergents, paints, adhesives etc.). Importers and downstream users placing the mixtures on the EU market must provide this information. Depending on the EU country, physicians, professional users and consumers can contact these appointed bodies to get recommendations for medical treatment in cases of poisoning.”
Some other key differences between the United States and EU:
Specific GHS hazard classes applicable. Even though most Hazard classes are the same in both EU and United States, there are a few that are not considered for one or the other. Example Pyrophoric gases category 1 is considered a hazard class for the United States, But not relevant for EU.
The United States has some slight differences in Pictograms than the EU, but most are very similar to each other.
There are also other responsibilities from the regulation of each country. EU has the REACH Regulation which is a regulation of the European Union, adopted to improve the protection of human health and the environment from the risks that can be posed by chemicals, while enhancing the competitiveness of the EU chemicals industry. The United States has an organization called Pipeline and Hazardous Materials Safety Administration (PHMSA). PHMSA's mission is to protect people and the environment by advancing the safe transportation of energy and other hazardous materials that are essential to our daily lives. To do this, the agency establishes national policy, sets and enforces standards, educates, and conducts research to prevent incidents. They also prepare the public and first responders to reduce consequences if an incident does occur.
Product Regulatory Services has expertise in all these area’s and can help your company work within the required regulations. We can first discuss which regulations are associated with your current business model. We can help build a strategic plan for your company growth to stay within the regulation.