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). The UN model is reviewed and revised frequently.
On May 25, 2012, the U.S. Occupational Safety and Health Administration (OSHA) revised and updated the Hazard Communication Standard (HCS) to align with Revision (Rev) 3 of the UN GHS. In May of 2024, OSHA issued a final rule amending HCS 2012 to align with Rev 7 and certain elements of Rev 8. The newly coined HCS 2024 implementation is staggered over the next several years, with final implementation expected by 2028. The business implications of the new rule are enormous, and companies need to think strategically and carefully about how to manage the many legal, regulatory, and communication challenges the new HCS presents.
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/OSHA HCS 2024 services
- WHMIS 2015/WHMIS 2023 services
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 L. 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 F. Baron, MSPH, and Heather F. 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 S. Vergnes, Ph.D., and Alexander E. Howard, M.S., who provide toxicology support to the classification, labeling, and SDS preparation process based upon decades of experience; and Karen L. 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.
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.
- Assess and revise SDSs for products marketed globally.