Andie Denk, Infotrac GHS Director

When OSHA adopted GHS in 2012, Revision 3 of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (the “Purple Book”) was used to create the regulation. In the past 10 years, there have been significant changes have been made through multiple revisions. OSHA is now proposing to adopt Revision 7 of the Purple Book. The goal of this update is to better align with other US agencies and international trading partners. OSHA has preliminarily determined that the proposed revisions to the HCS will reduce costs and burdens while also improving the quality and consistency of information provided to employers and employees regarding chemical hazards and associated protective measures. While the regulatory update has stalled at this time, below are the highlights. As we enter 2023, please know INFOTRAC will continue to monitor the Federal Register daily and supply updates as they are published.

Labels on shipped containers: OSHA is proposing to update paragraph (f)(11) to provide that chemicals that have been released for shipment and are awaiting future distribution need not be relabeled to incorporate new significant information about hazards; however, the chemical manufacturer or importer would still have to provide the updated label for each individual container with each shipment. This proposal would also require that the date a product is released for shipment be included on the product label.

Small container labeling: provisions added for GHS labeling on small containers. The proposal would provide that labels for small containers less than or equal to 100 ml capacity must include just the product identifier, pictogram(s), signal word, chemical manufacturer’s name and phone number, and a statement that the full label information for the hazardous chemical is provided on the immediate outer package.

Classification categories updated: Aerosols- update classification criteria to include category 3 non-flammables.

Specific Concentration Ranges: These ranges are consistent with those used in Canada, first described under the WHMIS 1988 Controlled Products Regulation (CPR) and reimplemented in 2018 under the HPR.

Revisions to hazard and precautionary statements: OSHA is proposing to revise a number of hazard and precautionary statements to align with the GHS Rev. 7.

HNOC Display on SDS: OSHA has proposed the allowance of HNOC classifications on US SDS. The symbol will be the exclamation mark and the signal word will be “warning.”  -ANDIE DENK, GHS DIRECTOR

These changes are only proposed until the final rule is released.  In the meantime, Infotrac is here to answer your SDS needs.  Give us a call or email [email protected]