Challenges of going global Complying with the new Global Harmonization Standard

On March 26, 2012, the Occupational Safety and Health Administration (OSHA) issued its Final Rule on the new Hazard Communication Standard, 29 CFR 1910, 1915, and 1926, FR Vol. 77, No. 58, page 17574. This Final Rule modified the existing Hazard Communication Standard to conform the United Nations' Globally Harmonized system (GHS) of Classification and Labeling of Chemicals. Per the Summary provided by OSHA, the modifications outlined in the action would "significantly reduce costs and burdens while also improving the quality and consistency of information provided to employers and employees regarding the chemical hazards and associated protective measures.'' While the aims as stated in the Summary and the modifications proposed seem minor there are some major challenges with the changes. As with any regulation or change, the challenges are not necessarily obvious to the common observer nor are they obvious to those charged with the implementation of the Final Rule.