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3.6 Hazard Communication

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At the heart of PS is risk management through the communication of hazards and handling recommendations to those handling chemical products throughout the supply chain. Hazard communication regulations exist in the many parts of the world. The fundamental requirement to develop and distribute SDSs for chemical substances and products and to supplement this information with product labeling are relatively mature and understood by many. It should be noted that even this requirement is still relatively new as evidenced by the Hazard Communication and WHIMS programs in the NAFTA region and the EU regulations in continental Europe. These requirements as written have only existed since the mid‐1980s. There are product labeling requirements administered by a range of agencies including the US Environmental Protection Agency (EPA), consumer product safety organizations, and food and drug agencies on a global basis (3).

The landscape and requirements for basic hazard communication have changed as GHS is implemented. GHS is an acronym for The Globally Harmonized System of Classification and Labeling of Chemicals (4). It was first adopted as an International Standard in 2002 and has been undergoing revisions and implementation by countries since that time. The GHS is a system for standardizing and harmonizing the classification and labeling of chemicals. To the extent that countries adopt the GHS into their laws, the regulatory changes would be binding for covered industries. However, “GHS compliant” Safety Data Sheets and labels are becoming a minimum for suppliers from many companies. It is anticipated that ALL existing hazard communication systems will need to be changed in order to apply the GHS. New country regulations will be based on GHS and generally consistent from region to region. The global effort required for this transition including input of product stewards and health professionals such as IHs has been very significant and may stay that way for some time.

Providing detailed hazard information to customers and/or other product handlers, including the general public continues to be a growing business to business requirement. The common elements of PS have expanded this aspect to include a higher level of responsibility to assure proper handling is understood and in fact practiced in the supply chain. In fact, a fundamental and somewhat contentious element of the Chemical Industry Association of Canada (CIAC) and ACC programs when first developed was the requirement to consider ceasing to do business with those who do not demonstrate the ability to safely handle the products sold to them. The first efforts at risk management include working with customers to foster safe handling of products and identifying and responding to recognized misuse of a product. However, if one failed in those efforts they should consider ceasing business with the offending company.

Patty's Industrial Hygiene, Program Management and Specialty Areas of Practice

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