The Globally Harmonized System for Classification and Labeling of Chemicals (GHS) is currently under revision for the sixth time. OSHA’s Hazard Communications Standard (HCS) aligns with the 3rd revision, and will be updated over time to reflect new versions of the GHS. Since the GHS revisions are ahead of the HCS updates, some companies may be tempted to update their own practices in line with the 4th revision of GHS in advance of a new HazCom standard. However, OSHA and the Society for Chemical Hazard Communication (SCHC) warned against this practice in a webinar they delivered in July of this year.
During the webinar, which was created to discuss a then-new OSHA HazCom Enforcement Directive, OSHA discussed the possible penalties for overachieving in your EHS programs. Because the current HCS does not align exactly with newer versions of the GHS, choosing to base your programming on GHS revision 4 rather than revision 3 could lead to serious citations due to hazard classification discrepancies.
OSHA’s warnings on this topic served a dual purpose: provided information about the pitfalls of working ahead on your GHS compliance system, and a reminder that GHS and safety compliance are a process rather than a one-time program. Updates over time are required for the best possible outcome. Staying in line with the law will benefit you more than financially; moving ahead on GHS alignment only after OSHA officially does will guide you through a gradual evolution toward a safer workplace.
