GHS chemical labels: Key dates for v7 in US and Canada
Learn about upcoming changes to GHS chemical labels & classification in the US & Canada – as well as steps companies can take now.
The 7th version of Globally Harmonized System of Classification and Labelling of Chemicals (GHS 7) was published in 2017 and varies in its status across the globe. While some regions are making moves to implement the changes to GHS chemical labels and classification, others are still considering the proposal.
United States: Close of comments 19 April.
At the time of posting this article, companies operating in the US have just less than 2 weeks left to comment on version 7 of Globally Harmonized System of Classification and Labelling of Chemicals (GHS 7).
By 19 April this year, businesses can share their perspective on the proposed changes through the Federal eRulemaking Portal, identified by Docket No. OSHA-2019-0001.
Proposed amendments to HazCom standard.
The US Occupational Safety and Health Administration (OHSA) proposes to align the federal hazard communication (HazCom) standard with GHS 7 chemical labels and classification rules by:
- Clarifying the purpose and scope of the standard by including national/international consensus standards (e.g., the European Agreement Concerning the International Carriage of Dangerous Goods by Road – ADR),
- Adding definitions, such as for bulk shipment, combustible dust, and immediate outer packaging,
- Detailing requirements related to the transport of hazardous chemicals,
- Adding labeling provisions for small containers,
- Adopting new requirements related to safety data sheet (SDS) preparation, and
- Integrating new provisions related to claiming concentration ranges as trade secrets.
What do changes mean for US companies?
Version 7 could bring big changes in GHS chemical labels and classification in the US. Companies would be subject to new and amended labeling and SDS requirements, most notably new requirements related to small container labeling.
For example, if the company ships containers with a capacity of less than or equal to 100ml, it would have to include at least the following information on those containers’ labels:
- product identifier,
- a signal word,
- the chemical manufacturer’s name and phone number, as well as
- statement that the complete label information for the hazardous chemical is provided on the immediate outer package.
Additionally, under the proposal, the company could store, rather than design, SDS to cover groups of hazardous chemicals in a work area.
Canada: Potential transition period & US collaborations.
For companies operating in Canada, the proposal’s commenting period to implement GHS 7 ended on 27 February 2021. The country’s next step is to amend its Hazardous Products Regulations (HPR) and Hazardous Products Act (HPA). Businesses can most likely anticipate a 2-year transition period after these proposed amendments come into force.
Modifications on the docket: definitions, hazard categories & testing.
Amendments to the existing requirements would include:
- Modifying several definitions,
- Adopting a new hazard category for non-flammable aerosols and new subcategories for flammable gases,
- Adding a new test procedure for oxidizing solids, and
- Updating the information elements required on SDS.
Once these amendments are in effect, companies will need to re-evaluate and revise product classifications, labels, and SDS to ensure continued compliance. As such, suppliers can anticipate initial costs in meeting the new requirements.
Syncing standards between Canada & the US.
Canada and the US are working together under their Regulatory Cooperation Council Joint Forward Plan to coordinate and synchronize the amended HPR with the coming into force of the updated US HazCom Standard. However, it’s possible that this won’t happen.
With companies manufacturing, importing, and distributing chemicals in the US facing earlier amendments than Canadian suppliers, the transition timelines could create complications. Any attempt at coordinating cross-border GHS chemical labels and classification would push some Canadian suppliers ahead of schedule. Those exporting hazardous products to the US would need to be aligned with the amended HazCom Standard before any changes to HPR or HPA go into effect.
Operating in Australia or New Zealand? Read what companies in these countries need to know to stay aligned with the new version: “GHS chemical labels: v7 changes in Australia and New Zealand”.