Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

GHS Memoranda
GHS Articles


Bergeson & Campbell, P.C. (B&C®) offers comprehensive global services in responding to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The manufacture, transport, labeling, and distribution of chemicals are a global business that must be managed correctly to avoid mishaps and ensure compliance. In 1992, the United Nations (UN) recognized, at the Rio Earth Summit, that developing the GHS on chemical classification, labeling, and handling of chemicals was the surest way to achieve international consistency on labeling and managing chemicals. The GHS is intended to standardize the criteria for classifying chemicals and hazard communication elements for material labeling and safety data sheets (SDS).

In the United States, the Occupational Safety and Health Administration (OSHA) issued a final rule aligning its Hazard Communication Standard (HCS) with the GHS in March 2012. OSHA's current HCS has been in place for three decades, since 1983. The rule became effective on May 25, 2012, and is based on UN GHS 3rd Revised Edition. Full implementation is expected by June 1, 2016.

In Canada, the Hazardous Products Regulation (HPR) was published in February 2015 and is based on UN GHS 5th Revised Edition. The Workplace Hazardous Materials Information System (WHMIS) has been in place since 1998 and was implemented at the federal level through the Hazardous Products Act (HPA) and the Controlled Products Regulations (CPR). The HPR repeals and replaces both HPA and CPR and is being referred to as WHMIS 2015. Full implementation is expected by June 2017.

In the European Union (EU), the Regulation (EC) No. 1272/2008 on Classification, Labeling, and Packaging of Substances and Mixtures (CLP) was issued December 16, 2008, and is based on UN GHS 4th Revised Edition. The CLP deadlines were split between substances and mixtures. Substances were expected to be in compliance by 2010, and mixtures in 2015. The regulation essentially repealed and replaced Directives 67/548/EEC and 1999/45/EEC.

GHS around the World:

Currently, more than 24 jurisdictions have adopted some form of the UN GHS model into their regulatory framework. Despite the effort to "harmonize," GHS requirements for each program are strikingly different and deadlines for implementation are applied at varying speeds and in frustratingly differing ways. It is critically important for stakeholders in the chemical community to understand GHS, track its implementation, and adopt corporate GHS systems timely and well.

Our Experience:

B&C, with its consulting affiliate, The Acta Group (Acta®), offers a global presence, with offices in North America, Europe, and Asia, that is key to our ability to advise and guide clients on GHS issues in every territory.

Our North American team includes Lynn Bergeson, who counsels clients on issues pertaining to chemical hazard, exposure and risk assessment, and risk communication, with particular expertise in nanotechnology and other emerging technologies. Karin Baron, M.S.P.H. and Heather Collins, M.S. are skilled in the assessment and application of GHS globally, including comprehensive knowledge of classification criteria, SDS development and templates, and labeling requirements. They are also well versed in the various requirements regarding the transport of dangerous or hazardous goods. Other members of the North American team include Jane Vergnes, Ph.D., DABT® who provides toxicology support to the classification, labeling, and SDS preparation process based upon decades of experience; Lara Hall, M.S., with ecotoxicology, environmental fate, and physical chemical properties experience to offer in support of GHS compliance; David Peveler, Ph.D., a chemist whose areas of specialization include UN GHS, CLP, and WHMIS 1988 compliant SDSs and labels; and Karen Lorusso, who assesses product formulations based on GHS, has experience with the transport of hazardous goods, and has extensive knowledge of classification criteria, SDS development, labeling requirements, and templates. Scott J. Burya, Ph.D., has managed compliance activities for a multinational coating manufacturer and is trained in the classification and labeling of hazardous materials according to the U.S. Department of Transportation (DOT), the International Air Transport Association (IATA), and the International Maritime Dangerous Goods (IMDG) codes.  

Our EU-based professionals include Emma Louise Jackson, CBIOL, MSB, who provides expertise regarding CLP, supply chain, and downstream user communication.

What We Do:

B&C offers comprehensive global solutions for complying with GHS regulations:

  • Substance classification to conform with UN GHS;
  • SDS preparation and/or review to ensure compliance;
  • Label formulation/review for UN GHS compliance;
  • UN GHS training;
  • UN GHS program development and strategic consulting;
  • EU CLP services;
  • OSHA HCS 2012 services; and
  • WHMIS 2015 services.

Representative Engagements:

  • Provided GHS training for a Fortune 50 company;
  • Provided comprehensive webinar on GHS and HCS obligations for a major trade association;
  • Routinely provide strategic global counseling on rationalizing GHS obligations across jurisdictional boundaries for product lines and businesses; and
  • Assess and revise SDSs for products marketed globally.

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