Background of GHS  

Not so long ago, working with hazardous chemicals was especially dangerous because, often times, employees didn’t know exactly what they were dealing with.   For example, the container may have come from a company in another country.

Even if they did label it, the message may have provided little in the way of helpful information. Workers would have to use their best judgment when transporting, storing, or extracting the chemical.

Then, in 1992, the United Nations decided to come up with a solution to this persistent problem. The result was GHS.

What Does GHS Stand For?  

GHS stands for Globally Harmonized System of Classification and Labeling of Chemicals. It is an internationally-recognized standard for labeling containers that hold hazardous materials. Currently, more than 65 nations have adopted some version of these standards. Although the original framework was published in 1992, the process of countries actually applying the standards has proven to be a long one.

What Does the GHS Do?  

It’s important to point out that the GHS is only a collection of guidelines and not legal obligations. Each country is free to apply them as they see fit.

That said, the GHS provides participating countries with a framework for creating a compliant hazard communication system. The main goal is to make it easy for workers to immediately understand what kind of chemical is in a container and what the risks are for handling it. This system covers:

  • Classifying
  • Labeling
  • Identifying

Before implementing the GHS, standards for labeling chemicals were different all over the world. If company A in Canada received a shipment of chemicals from company B in Germany, the different label types could make it confusing to figure out what exactly is in a container.

Unfortunately, any amount of confusion when moving or otherwise handling dangerous chemicals can result in major problems, including death. Keep in mind, too, that some companies do nothing but transport and handle these types of chemicals, so a consistent method for quickly labeling and identifying them is important.

Furthermore, shipments would often get stalled at different borders because one country’s laws about certain chemicals and to transport them would differ from another’s.

In short, the GHS ensures that a chemical originating from the U.S. is labeled the same way it would in China. While various countries may still have differing laws about different chemicals, these labels streamline the process of assessing their associated risks.

GHS Safety Data Sheets (SDS)  

Another component of the GHS is the Safety Data Sheet (SDS). These sheets provide important information about chemical hazards through 16 different sections, including:

  • Identification
  • Hazard Identification
  • Composition/Information on Ingredients
  • First-Aid Measures
  • Fire-Fighting Measures
  • Accidental Release Measures
  • Handling and Storage
  • Exposure Controls and Personal Protection

The main purpose of an SDS is to give workers instructions for dealing with potential worst-case scenarios like direct exposure to the chemical or a major accident.

HazCom 2012 in the United States  

In the United States, OSHA utilized GHS resources to create a comprehensive update to the prior protocol, the Hazard Communication Standard. This was done in 2012 after decades of work was undertaken to revise “HazCom.” This process is a good example of how a country could work within the GHS framework to create laws that fit their unique needs best.

This new standard is generally referred to as “HazCom 2012.” One of the biggest changes was an emphasis on ensuring employees who work with or near hazardous chemicals understand the risks involved.

Dr. David Michaels, the director of OSHA, confirmed as much during the speech he gave to introduce the Hazard Communication Standard (HCS). He mentioned that the first version that past in 1992 gave workers the right to know about these chemicals, but that this new version would ensure they also understood what these chemicals were capable of and what to do in case of an accident.

Nonetheless, it took four more years for the OSHA Hazard Communication Standard to become aligned with GHS standards and enforced as law. This timeline is understandable, though, seeing as how the changes OSHA made affected 43 million employees across 5 million different workplaces.

The biggest changes to the old procedures centered on:

  • Training
  • Safety Data Sheets
  • Labels
  • Hazard Classification

The related dates of compliance were spread out across four deadlines:

  • December 1, 2013: Employers had to train workers in reading and understanding GHS labels and data sheets
  • June 1, 2015: Distributors were given six months to ship old inventory before they had to join chemical manufacturers in completing hazard reclassification and producing GHS labels and data sheets.
  • December 1, 2015: The grace period for distributors ended and the companies had to begin complying with GHS requirements.
  • June 1, 2016: Complete GHS-alignment was achieved and full compliance by employers was now law. This included training workers on new hazards and any required updates to their hazard communication programs.

Therefore, at this time, every company that labels containers storing chemicals must follow HazCom 2012’s rules. While GHS standards are only a guideline, HazCom 2012 is a legal mandate.

GHS Standards in Other Countries  

As we touched on earlier, the GHS isn’t international law. The hope is that all members of the UN will eventually adopt these guidelines in their entirety, but countries are free to pick and choose which recommendations they wish to apply as law.

GHS Classification Categories  

A GHS classification is used by manufacturers to communicate the main risks involved with a specific chemical. Some examples of these classifications would include:

  • H281: Contains refrigerated gas; may cause cryogenic burns or injury
  • H305: May be harmful if swallowed and enters airways
  • H372: Causes damage to organs through prolonged or repeated exposure
  • H401: Toxic to aquatic life
  • H412: Harmful to aquatic life with long-lasting effects

This information is provided where the GHS hazard statements go, which we’ll cover in more detail in the following section.

The letter-number combination that precedes the GHS hazard classification is only for reference. There are 80, so these “H codes” make it easier to find the appropriate label. The European Union has another 26.

However, it’s the actual statement that must appear on the label in order for it to comply with the GHS framework.

In total, there are 29 GHS classification categories for unique hazards. These are broken down into three main categories:

Physical Hazards
  • Explosives
  • Flammable Gases
  • Aerosols
  • Oxidizing Gases
  • Gases Under Pressure
  • Flammable Liquids
  • Flammable Solids
  • Self-Reactive Substances
  • Pyrophoric Liquids
  • Pyrophoric Solids
  • Self-Heating Substances
  • Substances which emit flammable gases after they come in contact with water
  • Oxidizing Liquids
  • Oxidizing Solids
  • Organic Peroxides
  • Corrosive to Metals
  • Desensitized explosives
Health Hazards
  • Acute Toxicity (Oral/Dermal/Inhalation)
  • Aspiration Toxicity
  • Carcinogenicity
  • Germ Cell Mutagenicity
  • Reproductive Toxicology
  • Respiratory or Skin Sensitization
  • Serious Eye Damage/Eye Irritation
  • Skin Corrosion/Irritation
  • Target Organ Systemic Toxicity – Repeated Exposure
  • Target Organ Systemic Toxicity – Single Exposure
Environmental Hazards
  • Hazardous to Aquatic Environment (Acute/Chronic)
  • Hazardous to the Ozone Layer

The GHS provides objective standards for classifying each of these categories.

What Are GHS Label Requirements?  

All hazardous chemical labels must be made with six different indicators. These GHS label requirements are meant to succinctly communicate key information about what is inside.

However, the GHS takes into consideration that, sometimes, it’s not possible to keep workers safe with only these six label requirements, which is why it also allows for supplemental information.

Sample GHS Label with numbers

1. Product Identifier  

This requirement identifies the actual hazardous chemical inside the container. It is up to the responsible party to decide how they will do this. Common methods include:

  • Chemical Name
  • Code Number
  • Batch Number

However, the same identifier must be used on the GHS label and the accompanying SDS under section 1.

2. GHS Signal Words  

GHS signal words clarifies the relative level of danger a hazardous chemical represents. There are only two GHS signal words, though:

  • Warning
  • Danger

The former is used for lesser hazards while the latter is for labeling those with greater degrees of severity.

GHS label requirements also specify that only one of these words can be used. Therefore, even if a chemical has two hazards associated with it – one requiring “Warning” and one requiring “Danger” – both GHS signal words will not appear on the label, only “Danger” as it is the more severe of the two.

3. Hazard Statements  

GHS hazard statements explain the nature of the chemical’s hazard. All GHS hazard statements that apply to a certain chemical must appear on its label. Unlike GHS signal words, there is no hierarchy wherein one statement would be sufficient to cover lesser hazards.

That said, to save space, these statements can be combined on GHS labels, so long as they still communicate the vital information.

Each hazard category has its own hazard statements, which supports the kind of consistency the GHS was created to provide in the first place. Again, though, some leeway is approved in order to improve readability and reduce redundancies when using GHS hazard statements.

4. Precautionary Statements  

The point of these descriptions is to quickly alert workers to the kinds of precautions they should take to minimize the chances of exposure, improper storage, or incorrect handling of the hazardous chemical.

There are four precautionary statements that can be used on GHS labels:

 

  • Prevention: Steps to take to protect against exposure
  • Response: What to do in the event of a spill or some other kind of accident that may lead to exposure
  • Storage: How to store the container to ensure it’s secure and doesn’t pose a threat
  • Disposal: How to dispose of the chemical safely

 

A forward slash (/) is used whenever a classifier wants to shorten statements, as in the case of lists. For example, the precautionary statement “Do not breathe fumes/sprays/mist” would mean, “Do not breathe fumes, sprays, or mist.”

Usually, different precautionary statements are to be read as independent of one another. However, the OSHA Hazard Communication Standard does allow for some flexibility. If necessary for the sake of readability and clear communication, statements can be combined or unnecessary ones left out.

5. Name, Address, and Telephone Number  

This is a fairly straightforward GHS label requirement. The party responsible for the container and its contents – whether that be the manufacturer, distributor, importer, etc. – must include their contact information on the label.

6. Pictograms  

These GHS symbols are used to quickly let workers know about the chemical inside, even if they’re not close enough to read the other information provided. The standard for these GHS symbols is to have a red square set on a point against a white background with a black symbol inside. The symbol must be big enough that it can be easily recognized by a worker.

Red squares set on a point that don’t contain images are not GHS symbols and these types of pictograms are prohibited from a container’s label.

The GHS symbols used by OSHA are used all over the world. Although nine are internationally recognized, though, OSHA only enforces the use of eight of them:

GHS Health Hazard Pictogram

Health Hazard  

This symbol identifies a chemical that is a carcinogen, reprotoxic, mutagen, respiratory sensitizer, an aspiration hazard, and/or toxic to organs.

GHS Flame Pictogram

Flame  

This symbol indicates that a chemical is flammable, self-heating, pyrophoric, emits a flammable gas, is an organic peroxide, and/or is self-reactive.

GHS Exclamation Mark Pictogram

Exclamation Mark  

This symbol means that a chemical is an irritant, will trigger an allergic reaction, is acutely toxic, has narcotic effects, irritates the respiratory tract, and/or is hazardous to the ozone layer.

GHS Gas Cylinder Pictogram

Gas Cylinder  

This symbol represents a gas that is under pressure.

GHS Corrosion Pictogram

Corrosion  

This is for chemicals that would be unsafe to touch and/or would prove corrosive to metals.

GHS Exploding Bomb Pictogram

Exploding Bomb  

This represents any chemical that is an organic peroxide, self-reactive, and/or explosive.

GHS Flame Over Circle Pictogram

Flame Over Circle  

This is for any chemical that oxidizes.

GHS Skull & Crossbones Pictogram

Skull and Crossbones  

This symbol is for chemicals that could be toxic or fatal.

GHS Environment Pictogram

Environment  

This is non-mandatory but represents the threat of aquatic toxicity.

Supplemental Information  

If a label producer feels as though there is other information that workers should know about when handling, transporting, or storing a chemical, the GHS framework provides room to supply it.

One common example may be an additional hazard that isn’t covered by the nine GHS symbols we just covered. Another is information about the kinds of protective gear workers should wear when handling the container. Other examples would include:

  • Expiration Date
  • Fill Date
  • Directions for Use

There is no specific format label makers must follow in order to comply, though. The only rule is that the supplemental information cannot detract from or contradict the required information GHS labels must include.

Container Types  

There are two types of containers GHS labels may appear on: primary and secondary. The rules for labeling these different types are slightly different.

Primary Containers  

Primary Containers - Blue steel barrels on pallet

Primary chemical containers include:

  • Bags
  • Cans
  • Bottles
  • Cylinders
  • Barrels
  • Drums
  • Boxes

These are the types of containers that are used to transport chemicals from the manufacturers. They should include all the relevant GHS requirements we covered above.

Labels provided by suppliers should never be removed, modified, or defaced. If one of these labels needs to be replaced, the new one must contain the same exact information.

Secondary Containers  

Secondary Containers - Plastic chemical gallon containers with green cap

These containers tend to be much smaller than primary ones. Common examples include:

  • Jars
  • Jugs
  • Spray Bottles

They usually contain chemicals that have been transferred from their primary container. Labels for these containers must still follow the applicable GHS framework, except when the following applies:

  • The chemical is used during the work shift of the employee who made the transfer
  • The employee who transferred the chemical is in the work area for the duration of its use
  • The secondary container remains in the possession of the employee who transferred it and within the work area

Companies are also given a lot of flexibility for how they wish to label secondary containers. They can strictly follow the GHS framework, adopt rules used by the supplier, or come up with some version of their own.

GHS Requirements for Small Containers  

GHS labeling for small containersIn the United States, there are no specific requirements for labeling small containers. The only instruction is that labels must be prominently displayed and legible. Unfortunately, this can provide quite the challenge for companies dealing with small bottles and vials.

Unlike in the European Union, there are no exceptions for these tiny containers. OSHA demands that labels on every container include its contents’:

  • Manufacturer’s Name and Phone Number
  • Pictogram(s)
  • Product Identifier
  • Signal Word

Fortunately, there are guidelines that accommodate the demands of smaller containers. The following options can be used to ensure that the required information accompanies containers that aren’t big enough to have traditional labels attached:

The primary container must also mention that further information is provided on its packaging’s label.

Of course, there could be still be situations where containers are too small for even this much information, but OSHA has provided further instructions for those.

Minimum Label Information  

The packages used to transport these small containers must feature labels with the following information:

  • Applicable label elements as described in 29 CFR 1910.1200(f)(1) must be clearly visible
  • Instructions for storing the small container inside the outer container that bears the complete label
  • Alternative labeling the manufacturer deemed necessary, provided it does not conflict with other required standards

The complete label on the outside of any package a small container is kept in must always be maintained.

How Other Countries Handle Small Containers  

Seeing as how GHS requirements are just guidelines, other countries have also interpreted them to accommodate companies that use small containers. Here are specifics for 11 other countries, including the EU:

  • Australia
    • No specification for what qualifies as a small container
    • Precautionary statements can be excluded
  • Canada
    • Small containers are any that are 100 ml or less
    • Precautionary and hazard statements can be excluded
  • China
    • Small containers are any that are 100 ml or less
    • Precautionary and hazard statements can be excluded
  • European Union
    • Small containers are any that are 125 ml or less
    • Precautionary statements, hazard statements, signal words,  and pictograms can be excluded
    • Certain elements can be excluded based on their GHS classification
  • Japan
    • No specification for what qualifies as a small container
    • Tags are recommended
  • Korea
    • Small containers are any that are 100 ml or less
    • Precautionary and hazard statements can be excluded
  • Malaysia
    • Small containers are any that are 125 ml or less
    • Precautionary and hazard statements can be excluded
  • Singapore
    • Small containers are any that are 125 ml or less
    • Product identifier and pictogram(s) are required
  • Taiwan
    • Small containers are any that are 100 ml or less
    • Precautionary and hazard statements can be excluded
  • Thailand
    • No specification for what qualifies as a small container
    • No exemptions are provided
  • Vietnam
    • No specification for what qualifies as a small container
    • Precautionary statements can be excluded

Adhering to GHS Requirements Doesn’t Need to Be a Challenge  

While the GHS framework was designed to be as user-friendly as possible, not every company has the resources to label their products. At Luminer, we can help. Our technological capabilities and experience as a leading label manufacturer ensure we can meet all your chemical labeling requirements — enabling you to maintain GHS and OSHA compliance while simultaneously satisfying your customers’ specific needs. Contact us today to learn more about how Luminer can support your unique labeling needs.