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					                                            GHS Update 2012

Jan. 24 update: The Office of Management and Budget’s Office of Information and
Regulatory Affairs (OIRA) has announced that its review of the Occupational Safety
and Health Administration (OSHA) revised hazard communication standard, which
implements the Globally Harmonized System of Classification and Labeling of
Chemicals (GHS), has been extended. While it is unclear at this time how much longer
OIRA will need, final action on the rule is expected in the near future.

The U.S. Occupational Safety and Health Administration (OSHA), on Oct. 25, 2011, submitted to the
White House Office of Management and Budget (OMB) its final rule that would change the Hazard
Communication Standard by adopting the “industrial” aspects of the Globally Harmonized System for
the Classification and Labeling of Chemicals (GHS).

Industry is eagerly anticipating publication of the final rule to learn what modifications have been made
to the rule to adapt it in the United States. Several of the most awaited questions to be answered are
the length of time OSHA will allocate for compliance with the rule for pure, intermediates, and mixtures;
if OSHA will require multicolored pictograms on labels; if OSHA will change the requirements for In-
Plant-Labeling; and if a totally compliant GHS label and safety data sheets (SDS) will be accepted by the
U.S. Environmental Protection Agency (EPA), the Consumer Product Safety Commission (CPSC), and
OSHA until such time as the EPA and CPSC adopt their portions of the GHS.

Of note, OSHA does not have jurisdiction or authority to adopt the portions of the GHS that deal with
environmental or consumer classifications. Additionally, EPA and the CPSC have not yet begun making
the regulatory and statutory changes of their regulations and laws to adopt their portions of the GHS.
For our industry, that will likely mean that our products will require both consumer and industrial labels
until the EPA and CPSC adopt their portions of the GHS.

The adoption of the GHS by the United States will have a significant impact on Material Safety Data
Sheets and product labels for both domestic and export products.

The UN’s intention in developing the GHS was to globally harmonize the world’s system for classifying,
labeling, and generating SDS for hazardous substances and mixtures. If all countries used the same
system and the same rules, then labels and SDSs throughout the world would differ in language only.
Unfortunately, as each nation adopts the GHS, they adopt it in parts or change parts of the original
system, thus creating global dis-harmonization.

                                                 -   Compliments of

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