October 28, 2011 - Welcome to a special edition of the 3E EH&S Express! Please forward this bulletin to any colleagues who might find it useful or have them request a subscription by clicking here. For information on how to opt-out, see the instructions at the end of this email.
3E RegReport
US OSHA Submits the Final Rule on GHS to Office of Management and Budget
On October 25, 2011, the United States' Occupational Safety and Health Administration (OSHA) sent the Office of Management and Budget (OMB) its final rule to adopt the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) for its Hazard Communication Standard (HCS). OMB now has up to 90 days to review and finalize the rule before the rule becomes published in the Federal Register by January of 2012.
Many countries around the world have already adopted the GHS into their regulatory systems, and the U.S. system will now be based on the same system, which will make the global HazComm compliance much easier for U.S. companies to facilitate.
3E Company anticipates that the new standard will have far-reaching implications for Material Safety Data Sheet (MSDS) and label authoring, publishing, distribution, and management. In addition, the promulgation of the final rule will affect millions of workplaces and have a profound effect on the supply chain. Upstream, manufacturers and distributors will be required to conform to new MSDS format and content requirements. Downstream, producers, importers, and distributors will have a three-year transition period to be in full compliance. The proposed rule also includes a provision that requires employers to train all employees on the new label elements and the standardized safety data sheet format within two years after the publication of the HCS final rule.
The OMB submission was publicly available on October 27, 2011, and can be viewed here.
3E Company has a wide range of resources available to support conformance with the revised Standard.
- To view a press release on the status of 3E's expanding GHS practice, please click here;
- To visit the GHS Solutions page on the 3E Web site, please click here;
- To view 3E's latest presentations, articles, and webinars on GHS, please visit our the 3E's EH&S Resource Center.
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