GHS Precautionary Statements
OSHA has included the GHS precautionary statements within
the HCS, even though these statements are not yet considered formally
harmonized. This means that you may use the
provided statements verbatim, or not. As
long as the statements that you do use align with the hazard, at this time,
that will suffice. The only caution this
author notes is the term “not yet considered” to be harmonized. Does this mean these statements will be
required verbatim soon…later…ever?
There is no clear answer to this question, but is does seem logical to
keep it in mind before discarding the provided statements. Remember, the GHS is alive and will likely be updated as time goes on. At this point OSHA states that the precautionary statements should be in the required format and
sequence. This sequence has well thought out reason. That being the presentation of certain information
in a particular order is beneficial to the end user, especially in the event of
an emergency. The idea is that once
trained on the SDS format and therefore the Labeling format, users will be also
trained on where to find important information. With these new rules and format
specifications, if an emergency occurs, users will no longer struggle to find
the information they need immediately. A
much needed improvement over past MSDS formats where every manufacture had a
unique way of providing data. Items
such as the hazard and first aid statements are important for the average user
and this stipulation is in congruence with the order of information in the
voluntary industry consensus standard for SDS IANSI Z400.1)
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
