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Comparison between EU CLP and US GHS adopted by OSHA

20 March 2012, The US Occupational Safety and Health Administration (OSHA) has finally released the final rule for its new Hazard Communication Standard (HCS) that includes hazard classification, labeling and safety data sheet requirements in compliance with the provisions of GHS. The updated standard will be published in the Federal Register on 26 March.

To help companies better understand the different classification, SDS and labeling requirements in EU and USA, CIRS has summarized the main differences between EU CLP and US GHS.

Transition periods

EU CLP REGULATION (EC) No 1272/2008

OSHA Hazard Communication Standard (HCS)

Substances

1st December 2010 – 1st June 2015
Suppliers must classify substances according to both DSD and CLP. They must label and package according to CLP.

1st June 2015 onwards
Suppliers must classify, label and package according to CLP.

 

Mixtures
20th January 2009 – 1st June 2015
Suppliers must classify preparations according to DPD, and may continue to label and package them according to DPD. However they may choose to classify, label and package mixtures according to CLP. In this case, CLP labeling must be used.

1st June 2015 onwards
Suppliers must classify, label and package mixtures according to CLP.

Substances and Mixtures

1st December 2013
Employees must be trained on the new label elements and safety data sheet (SDS) format before this date.

1st June 2015 onwards
Suppliers shall classify, label and package chemicals according to the updated HCS (except distributors).

1st December 2015 onwards
The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label.

During the phase-in period, companies would be required to be in compliance with either the existing HCS or the revised HCS, or both. Employers are not required to maintain two sets of labels and SDSs for compliance purposes.

Building blocks

Differences of Building Blocks between US GHS and EU CLP

Important Note: China GHS is not included in this table because China's new GHS standards might be published later this year or next year. The new standards are based on the 4th edition of UN GHS.

Safety Data Sheets

EU CLP REGULATION (EC) No 1272/2008

OSHA Hazard Communication Standard (HCS)

  • 16 sections are mandatory.
  • EU supplementary hazard statements must be disclosed in section 2.
  • For substances, classification in accordance with both DSD and CLP must be given in SDS until 2015.
  • National occupational exposure limit values, DNELs and PNECs are required.
  • Exposure scenarios are required if available.

 

  • Sections 12-15 may be included in the SDS, but are not required by OSHA.
  • Material safety data sheets will be renamed as safety data sheet.
  • "Hazards Not Otherwise Classified (HNOC)"need to be disclosed in section 2 of SDS, but are not required on a label;
  • Substances can be classified in compliance with either the existing HCS or the revised HCS until 2015.
  • American Conference of Government Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), OSHA permissible exposure limits (PELs), and any other exposure limit are required.
  • Environmental hazards are not required.

 

For more detailed information about US GHS, please register for SCHC's webinars.

http://www.schc.org/

References and more readings

Hazard classification criteria for the updated HCS

http://www.osha.gov/dsg/hazcom/ghs-final-rule.html

A comparison between the old HCS and revised HCS

http://www.osha.gov/dsg/hazcom/side-by-side.html

A comparison between a current label and a new label to be used in US

http://www.osha.gov/Publications/HazComm_QuickCard_Labels.html

ECHA CLP Regulation

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do....DF

ECHA guidance on classification and labeling of chemicals

http://echa.europa.eu/web/guest/regulations/clp/labelling

Differences between the 4th Edition of UN GHS, CLP Regulation and China GHS

http://www.cirs-reach.com/news/...and_china_ghs_summarized_by_cirs.html

Understanding Cut-off Value and Concentration Limits in CLP Regulation and China GHS

http://www.cirs-reach.com/CLP...20China%20GHS.pdf

If you have any questions, please consult:

  • Mr. Yunbo Shi, Europe Office
    Singleton House, Laurence Street, Drogheda, Co. Louth, Ireland
    Tel : +353 41 9806 916 | Fax : +353 41 9806 999
    Email: yunbo.shi@cirs-reach.com

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