GHS...it's alive!
OSHA calls special attention to the fact that the GHS is a "living document". They state that the UN actively reviews and updates the GHS document every two years. The version of the GHS that has been adopted by OSHA is Version 3. Version 3 was originally adopted by the UN in 2008. However, the UN published Version 4 in 2010. While OSHA does not specifically state what the differences are between Versions 3 and 4, they do state that alternative rule-making procedures may be implemented to adopt what they call non-substantive changes or clarifications. OSHA does not go into great detail here. What we do know is that we have plenty of time before final implementation of GHS here in the United States. But in that time, there is potential for more changes...does this mean that the very rule we are all working on implementing will change before we have completed implementation? It is doubtful even OSHA has an answer to this question. What OSHA does say is that any major changes will be opened up for standard comment and procedure.
The fact is, GHS is a living, breathing, changing rule and we are all best to keep our eyes and ears open.
Next week's topic....
State vs Global...
This information is offered for evaluation and discussion
only. For more information contact your local OSHA representative or
go to http://www.osha.gov/dsg/hazcom/index.html
