HCS & GHS Frequently Asked Questions
What is Hazcom?
Hazcom, better known as the Hazard Communication Standard (HCS), requires employers to disclose hazardous and toxic chemicals in workplaces. HCS is designed to improve the awareness and safety of all workers, especially those who are working in occupations that involve multiple hazardous chemicals.
The HCS is intended to address the issue of classifying the hazards of chemicals, communicate information of such hazards and appropriate protective measures to workers. [1910.1200(a)(2)]
More things to know about HCS…
The HCS is composed of several elements. The HCS includes, but is not limited to, a written hazard communication program, lists of hazardous chemicals in the workplace, labeling of chemical containers and preparation and distribution of safety data sheets to employees and employers, and employee training programs. [1910.1200(a)(2)]
Is the HCS required in all businesses?
The Office of Safety and Health Administration (OSHA) does not specifically state that all businesses should have a Hazcom. However, OSHA mandates that institutions that have any known hazardous chemical in the workplace present in a manner that puts employees in risk of exposure under normal conditions of use or in an emergency to comply with HCS. [1910.1200(b)(2)]
What about GHS? Is it similar to HCS?
GHS stands for Globally Harmonized System of Classification and Labelling of Chemicals. It also defines hazards of chemicals (more details below). GHS is the internationalized version of HCS, and both share a similar goal. GHS is inline with several local chemical safety standards in many other countries. The HCS is the standard used in the United States, and is now part of the GHS.
Is HCS applicable to chemicals that will be moved out of the workplace?
OSHA specifically states that chemicals that are transported in and out the workplace must be covered by the HCS. All chemical containers, including those that will be transported out of the workplace, must have proper labels that are not defaced or damaged. Transported containers must have their own safety data sheets. [1910.1200(b)(3)(i)] [1910.1200(b)(3)(ii)] [1910.1200(b)(3)(iv)] [1910.1200(b)(4)(i)]
Who classifies the hazards of chemicals in the workplace?
Manufacturers, distributors and importers determine and classify the hazards of chemicals. They have to provide the hazard class and associated hazard category to labels of hazardous containers. They also ensure each hazardous container is labeled, tagged or marked. [1910.1200(d)(3)(i)] [1910.1200(f)(1)]
Who maintains the written hazard communication program?
Employers must develop, implement and maintain a written hazard communication program at the workplace. Employers must inform employees about the hazards of non-routine tasks and chemicals used in work areas.
In workplaces with multiple employers, like construction sites, employers must ensure that hazard communication programs like safety data sheets, teaching of precautionary measures and labeling systems are available for easy access by ALL employees on-site. [1910.1200(e)(1)] [1910.1200(e)(2)]
What are the instructions for labels on shipped containers?
Chemical manufacturers, importers and distributors are required to provide the following information on containers of hazardous chemicals:
- Product identifier
- Signal word
- Hazard statement(s)
- Precautionary statement(s)
- Name, address, and telephone number of the chemical manufacturer, importer or other responsible party
Can anyone change the information on the labels of hazardous chemicals?
Aby changing information on labels of hazardous chemicals must be only performed when necessary. For example, the employer shall not remove or deface existing labels on incoming containers of hazardous chemicals, unless the container is immediately marked with the required information.
Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information. If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again. [1910.1200(f)(9)] [910.1200(f)(11)]
Who develops safety data sheet for hazardous chemicals?
Manufacturers and importers of hazardous chemicals are responsible for developing or obtaining safety data sheets for each hazardous chemical they produce or import. They must ensure that safety data sheets are in the English language (copies in other languages are allowed). [1910.1200(g)(1)] [1910.1200(g)(2)]
What information should be on a safety data sheet?
Manufacturers, distributors and employers preparing safety data sheets must ensure that the information provided is accurate and has scientific basis. Chemical manufacturers or importers are required to provide information based on the following section numbers and headings. The safety data sheet should contain the following, where applicable:
Section 1 Identification
Section 2 Hazard identification
Section 3 Composition/information on ingredients
Section 4 First-aid measures
Section 5 Fire-fighting measures
Section 6 Accidental release measures
Section 7 Handling and storage
Section 8 Exposure controls and personal protection
Section 9 Physical and chemical properties
Section 10 Stability and reactivity
Section 11 Toxicological information
Section 12 Ecological information
Section 13 Disposal considerations
Section 14 Transport information
Section 15 Regulatory information
Section 16 Other information, including date of preparation or last revision
If no relevant information is found for any sub-heading within a section, the manufacturer, the distributor or employer will mark to indicate that no applicable information was found. [1910.1200(g)(5)] [1910.1200(g)(2)] [1910.1200(g)(3)]
What about safety data sheets for complex mixtures?
For chemical ingredients that are essentially the same, but the exact composition varies from mixture to mixture, the manufacturer, distributor or employer may prepare one safety data sheet for all of these similar mixtures. [1910.1200(g)(4)]
Employers must train employees on hazardous chemicals
Employers must train employees on information and safety training on chemicals in the work area at their initial assignment, and whenever a new chemical hazard is introduced in the workplace. Employees must be informed on how to work with hazardous chemicals in the operation area, and location and availability of written hazard communication programs. Employers have to inform employees about the details of the hazard communication program.
Employers must also train employees on how to detect the presence or release of hazardous substances in work areas, hazards to health of the chemicals and protective measures. [1910.1200(h)(1)]
What about those chemicals considered trade secrets?
Manufacturers, distributors or employers may withhold the identity of chemicals treated as trade secrets provided that:
- There is supporting evidence that the chemical is a trade secret.
- The properties and effects of the hazardous chemical must be disclosed.
- The safety data sheet indicates that the specific chemical identity and/or percentage of composition are being withheld as a trade secret.
Most importantly, trade secret chemicals must be disclosed to medical professionals in case of exposure or in an emergency. In non-emergency situations, the identity of the hazardous chemical should be disclosed to medical professionals, employees or their representatives if:
- There is a written request.
- Used to assess hazards of the chemical(s).
- Used to conduct or assess sampling of the workplace atmosphere to determine exposure levels.
- Used for medical treatment of exposed employees.
- Used to design or assess engineering or protective measures for exposed workers.
- Used to determine exposure levels and treating harmful exposures
- The request includes a description of procedures to maintain confidentiality of disclosed information.
The persons who will know the identity of chemicals treated as a trade secret must agree in a written confidentiality agreement not to use the trade secret information for any purpose other than the health need and not to release information except to OSHA. [1910.1200(i)]
What is the effective date of revised HCS regulations?
Employers must have trained all employees about the new label elements and safety data sheets by December 1, 2013.
Chemical manufacturers, distributors and employers must comply with all the modified HCS regulations no later than June 1, 2015. [1910.1200(j)]
What is GHS?
GHS or the Globally Harmonized System of Classification and Labelling of Chemicals is an international system for standardizing and harmonizing classification and labelling of chemicals in United Nations member countries.
The GHS can be described as the international version of the HCS (Hazard Communication Standard) used in the United States. The HCS is aligned with the terms of the GHS.
However, the GHS is not a regulation or a standard. Rather, it contains the agreed hazard classification and communication provisions, and information on how to apply them.
Does GHS cover all hazardous chemicals?
The GHS covers all hazardous chemicals. The GHS states that ‘all types of chemicals will be covered’ and ‘protection will not be reduced’.
When will the GHS be implemented?
The GHS is not a standard nor a regulation, so therefore it has no implementation schedule. The GHS is designed to tie into different chemical safety regulations in UN countries. All existing systems have to develop strategies to phase into the new GHS requirements.
How is the GHS to be applied?
The GHS is composed of the following programs:
- GHS classification (identifying intrinsic hazards of chemicals)
- Hazard communication (safety data sheets and labels)
- Risk management systems (risk communication and exposure monitoring/control)
- Safe use of chemicals
What is GHS classification?
It is the identification of hazards of a chemical or mixture. The GHS uses the following criteria in assigning a category of hazard/danger of a chemical:
- Physical hazards
o Flammable gases
o Flammable aerosols
o Oxidizing gases
o Gases under pressure
o Flammable liquids
o Flammable solids
o Self-reactive substances
o Pyrophoric liquids
o Pyrophoric solids
o Self-heating substances
o Substances that emit flammable gases upon contact with water
o Oxidizing liquids
o Oxidizing solids
o Organic peroxides
o Corrosive to metals
- Health hazards
o Acute toxicity
o Skin corrosion/irritation
o Serious eye damage/eye irritation
o Respiratory or skin sensitization
o Germ cell mutagenicity
o Reproductive toxicology
o Target organ systemic toxicity – single exposure
o Target organ systemic toxicity – repeated exposure
o Aspiration toxicity
- Environmental hazards
o Hazardous to aquatic environments, acute, chronic or both
What is the GHS approach to mixtures?
The GHS physical hazard criteria also apply in identifying hazards from mixtures, and use the following tier approach to classify mixtures:
Generally, use test data for the mixture, if available
Compare to substance hazard criteria, or use bridging principles if applicable
Estimate hazards based on the known component information
What is a bridging principle?
Bridging principles are used in the GHS to identify hazards of untested mixtures. When a mixture has not been tested, but there is sufficient data on the components and/or similar tested mixtures, the data can be used in accordance with the following bridging principles:
- Dilution: If a mixture is diluted with a diluent that has an equivalent or lower toxicity, then the hazards of the new mixture are assumed to be equivalent to the original.
- Batching: If a batch of a complex substance is produced under a controlled process, then the hazards of the new batch are assumed to be equivalent to the previous batches.
- Concentration of Highly Toxic Mixtures: If a mixture is severely hazardous, then a concentrated mixture is also assumed to be severely hazardous.
- Interpolation Within One Toxic Category: Mixtures having component concentrations within a range where the hazards are known are assumed to have those known hazards.
- Substantially Similar Mixtures: Slight changes in the concentrations of components are not expected to change the hazards of a mixture and substitutions involving toxicologically similar components are not expected to change the hazards of a mixture.
- Aerosols: An aerosol form of a mixture is assumed to have the same hazards as the tested, non-aerosolized form of the mixture unless the propellant affects the hazards upon spraying.
If bridging principles are not applicable or cannot be used, the hazards should be estimated based on component information.
What are the label elements in GHS?
GHS standardized labels must have the following:
- Product name or identifier
- Signal word (‘Warning‘ for less severe hazards, or ‘Danger’ for more severe hazards)
- Physical, health, environmental hazard statements
- Supplemental information (non-harmonized information not required or specified by the GHS)
- Precautionary measures and pictograms (measures to minimize or prevent adverse effects)
- First-aid statements
- Name and address of company/supplier
- Telephone number of supplier
How to describe multiple hazards on GHS labels
Where a substance or mixture presents more than one GHS hazard, there is a GHS precedence scheme for pictograms and signal words. For substances and mixtures covered by the UN Recommendations on the Transport of Dangerous Goods, Model Regulations, the precedence of symbols for physical hazards should follow the rules of UN Model Regulations. For health hazards, the following principles of precedence apply for symbols:
- if the skull and crossbones applies, the exclamation mark should not appear;
- if the corrosive symbol applies, the exclamation mark should not appear where it is used for skin or eye irritation;
- if the health hazard symbol appears for respiratory sensitization, the exclamation mark should not appear where it is used for skin sensitization or for skin or eye irritation.
If the signal word ‘Danger’ applies, the signal word ‘Warning’ should not appear. All assigned hazard statements should appear on the label. The “competent authority” may choose to specify the order in which they appear.
Does the GHS require a label format or layout?
No. The GHS only specifies that there must be hazard pictograms, signal word and hazard statements located on the label.
Can anyone vary the applications of the components of the GHS?
The GHS states that ‘competent authorities’ may vary the application of GHS components according to type of product (industrial, pesticide, consumer, etc.) or industry (workplace, farm, retail store, etc.) or lifecycle of the chemical.
Are chemical containers in the workplace covered by the GHS?
Yes. In addition, products covered by the scope of GHS must carry the GHS label when supplied to the workplace. Employers can also choose to display label information in the work area rather than on individual containers.
Do I have to use the GHS Safety Data Sheet?
If you are already in compliance with the Safety Data Sheet of the HCS, then you do not have to use an additional GHS Safety Data Sheet. Keep in mind that the HCS is part of the GHS.
How does the GHS address trade secrets or confidential business information?
The GHS states that it does not harmonize mechanisms for protection of trade secrets or confidential business information. Refer to the HCS to find out how to address such confidential information.
Do employers have to train workers on GHS regulations?
Yes. Employers have to train workers to recognize and interpret safety data sheets, as well as take appropriate actions to address chemical hazards.