Meeting GHS compliance obligations

CGI helps global chemical manufacturers develop achievable compliance strategies

 Companies who manufacture, distribute or use hazardous chemicals must comply with a variety of global regulations regarding the assessment and communication of hazards. The Globally Harmonized System for the Classification and Labeling of Chemicals (GHS), first published by the United Nations Economic Commission for Europe (UNECE) in 2003, is a sweeping initiative with two main objectives:

  1. Consistently present chemical classification by type of hazard, and
  2. Communicate classifications through harmonized communication elements, including labels and safety data sheets. 

Since the GHS was first published, countries have been adopting aspects of the system and incorporating its principles into their various hazard communication regulations. To date, 67 countries are in various stages of implementation.

Two major economic markets, the European Union and the United States, have enacted legislation to implement the GHS principles using a phased approach which enforces full adoption by 2015.  The table below provides key information and dates around both E.U. and U.S. implementation of GHS.

These transformative regulatory changes require companies to start planning now to meet their compliance obligations. Having supported the hazard communication and regulatory compliance requirements of global chemical manufacturers for more than 15 years, CGI has the right combination of resources, experience and tools to help you build a successful and achievable GHS compliance strategy. For more information, please contact us at EHS@cgi.com.

GHS Adoption activities 
United States European Union
Regulation: OSHA Hazard Communication Standard 2012 Classification, Labeling, Packaging of Substances and Mixtures (CLP)
Impact:
  • Updates the Hazard Communication Standard to align with  the GHS
  • Moves from a performance-oriented standard to a specifications standard
  • Include conforming updates to:
    • substance-specific health standards
    • a wide range of safety standards; from Process Safety Management to flammable liquids
  • Require re-assessment of all Substances and mixture covered by the standard for classification
  • Require updating all Safety Data Sheets and Labels
  • A new regulation which aligns hazard classification and labeling with the GHS and repeals the Dangerous Substance and Preparations Directives
  • Includes conforming updates to the EU Safety Data Sheet requirements in Annex II of REACH which incorporate GHS elements into the EU Safety Data Sheet
  • Requires re-classification of all Substances and Mixtures covered by the CLP regulation
  • Requires updating all Labels
 
Key Transition Dates*:
December 1, 2010 - Substance Classification and Labeling
December 1, 2012 - Labeling for substances on the shelf
December 1, 2013 Training employees on new label and SDS
June 1, 2015 Substance and Mixture Classification, SDS and Labeling Mixture Classification and Labeling
December 1, 2015 Labeling for substance and mixtures on the shelf
June 1, 2017 Labeling for mixtures on the shelf
Consequences: Non-compliance can result in OSHA citations and fines Non-compliance is dependent on Member State enforcement policies but can result in fines and/or a ban on selling a substance or mixture

* Compliance with new regulation required by the dates listed. Generally a transition period allows companies to comply with either the old or new regulation during the transition period.