On June 12, 2013 the Occupational Safety & Health Administration (“OSHA”) held an open informal public meeting of the U.S. Interagency GHS (Global Harmonization System of Classification and Labeling of Chemicals) Coordinating Group. The purpose of this meeting was to provide interested groups and individuals with an update on GHS-related issues and an opportunity to express their views for consideration in developing U.S. Government positions for the upcoming 25th session of the United Nations Sub-Committee of Experts on the Globally Harmonized System of Classification and Labeling of Chemicals (“UNSCEGHS”).
OSHA and the GHS coordinating group will consider all comments and information gathered to develop U.S. government positions on the four working papers to be discussed at the UNSCEGHS meeting. UNSCEGHS will base its decisions on the working papers. These decisions will affect the regulation of matters pertaining to the transportation of dangerous goods (“TDG”) and GHS. The transportation of dangerous goods must be regulated in order to prevent accidents to persons, property, and damage to the environment.
Four working papers were discussed at the meeting. OSHA sought input from interested groups and individuals as they have not yet developed a position on these items.
Germany submitted a document concerning articles as environmentally hazardous substances. An article is defined, in OSHA Hazard Communication Standard (HCS) (29 CFR 1910.1200), as a manufactured item other than a fluid or particle. In this document, Germany requests that the experts of the Sub-Committee (of Experts on the Transport of Dangerous Goods) indicate whether the criteria for environmentally hazardous substances should apply to articles. Several industry representatives voiced that it was their position that GHS does not include articles.
The second paper, from the experts in Sweden, suggests an editorial clarification of a screening procedure for potential explosives in the Manual of Tests and Criteria and in the GHS. The proposed new wording is unambiguous and achieves the proper selection. While OSHA has not developed their own position on this matter, representatives expressed that OSHA’s position will depend heavily on the positions of the TDG and GHS.
The third paper was submitted by France. The paper was an introduction of the issues with nanomaterials and an overview of knowledge on the subject. The panel was still in the process of reviewing the material and no discussion was had.
The final paper was also on nanomaterials. This paper, from Australia, presents the country’s position on the classification and hazard communication of nanomaterials and the applicability to GHS. Industry representatives were not clear as to why GHS does not classify nanomaterials yet. OSHA representatives stated that nanomaterials are still at the early stage and under development, but that a working group has been developed to discuss the subject.
For more information on OSHA, GHS, or the TDG, please contact Ronce Almond at (202) 457-7790.