I'd like to continue discussing the Global Harmonized System (GHS) for hazard classification and communication. I want to acknowledge that the following information comes from the United Nations website.

Purpose of the GHS

As noted last week, the GHS is an attempt to harmonize criteria for the classification of substances and mixtures according to their physical, health and environmental hazards as well as for communication elements (including requirements for labels and safety data sheets). The UN lists the purposes of the GHS as:

• Enhancing the protection of human health and the environment by providing an internationally comprehensible system for hazard communication;
• Providing a recognized framework for countries without an existing system;
• Reducing the need for testing and evaluation of chemicals; and
• Facilitating international trade in chemicals whose hazards have been properly assessed and identified on an international basis.

Scope of the GHS

The GHS is intended to benefit persons exposed to hazardous substances including consumers, workers and emergency responders. The GHS has two main elements: hazard classification and hazard communication.

Hazard Classification: GHS classification uses four sub elements:

• Health hazards;
• Environmental hazards;
• Physical hazards; and
• Mixtures.

Hazard Communication: Like WHMIS in Canada and HazCom in the U.S., the GHS hazard communication scheme involves the use of labels and safety data sheets. (Note: The latter are referred to as "safety data sheets," not "material safety data sheets." The "M" has been dropped from the "MSDS.") GHS labels are similar to but not exactly the same as WHMIS and HazCom labels. The major difference: GHS labels use health and environmental warning symbols. (You can view the new warning pictograms at http://www.unece.org/trans/danger/publi/ghs/pictograms.html )

The Adoption of GHS

Note that GHS is about classification and communication of hazards. It's not about risk management. For example, it doesn't recommend exposure limits that should be adopted for various substances. Nor does it say how consumers and workers should be trained. The adoption of exposure levels, training requirements and other risk management and operational details is left to each country.

Ultimately, each country must decide which, if any, of the GHS classification and communication elements to adopt. Countries like Canada and the U.S. can integrate GHS into their current regulatory schemes. Countries that don't have full blown schemes can build a regulatory regime around the GHS elements if they choose.

Caveat: Countries must ensure consistent application of the GHS elements that they do adopt across their systems. For example, if a national system covers the carcinogenicity of a chemical, it should follow the GHS's harmonized classification scheme to classify it and its harmonized label elements to communicate its dangerous properties. Allowing for inconsistencies from nation to nation would undermine the GHS goal of international harmonization.

Conclusion

I hope this little summary gives you a feel for what GHS is all about. If you want more information, I suggest you visit the UN website: http://www.unece.org/trans/danger/publi/ghs/ghs_rev01/English/01e_part1.pdf.

SPOT THE VIOLATION
An MSDS Quiz

By Glenn Demby

SITUATION

A safety director takes inventory of hazardous substances and verifies that there's a complete, up-to-date MSDS for each one. MSDSs are assembled into a binder and kept in the manager's office. The safety director reminds workers and the company's safety committee that she'll gladly give the binder to anybody who wants to see an MSDS.

QUESTION

Which of the safety director's acts (or omissions) violated HazCom/WHMIS?

A. Not independently verifying accuracy of the information in the MSDS
B. Not preparing a company version of each MSDS
C. Making workers ask for MSDS instead of giving them direct access
D. Keeping MSDS in a paper binder rather than a computer system

ANSWER

C

EXPLANATION

HazCom & WHMIS require employers to make MSDS readily accessible to any worker who may be exposed to hazardous chemicals and substances. "Readily accessible" means that workers must have access to the MSDS when they're in work areas during work shifts. The worker should be able to see MSDSs without having to rely on somebody else. Keeping MSDSs in the office of a safety director or any other individual is problematic because that office may be far from the shoproom floor or even off the premises. The office might also be kept locked during certain shifts.

WHY WRONG ANSWERS ARE WRONG

A is wrong because OSHA and WHMIS allow employers to rely on MSDS information they get from their suppliers without having to analyze or evaluate a hazardous substance independently.
B is wrong because while companies can, they don't have to create a company version of an MSDS.
D is wrong because while making MSDS sheets available to workers via a computer terminal is an option (provided that the employer takes certain steps like making sure the equipment constantly works), it isn't mandatory.

MEMBER REPLY

Don't Blame Paving Contractor for Minneapolis Bridge Collapse

Responding to the comments of the author of "Show More Sympathy" for the victims of the I35W Bridge disaster, I feel like the public is pointing the finger at the re-surfacing contractor. Anyone familiar with road and bridge construction knows that re-surfacing is primarily a superficial and cosmetic service. Yes, they were "repairing" the asphalt. They were NOT repairing the Bridge itself. The implication that the re-surfacing contractor caused the collapse is ludicrous.

If the state/city/county government were to shut down traffic every time the road or bridge needed paving, traffic would come to a complete standstill and the loss of productivity and revenue would carry implications far greater than many would ever consider.

This is a great tragedy. No one can deny that. Let's all show some sensible courtesy and not jump headlong into the blame game without all of the facts. Before any blame should be placed, we should all allow the NTSB inspectors to do their job, which is to investigate and determine the cause.

Evelyn Robertson

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