The clock is well and truly ticking on the implementation of the Global Harmonized System in the US via HAZCOM 2012. Though the regulation was adopted in 2012, the time line for the implementation of this legislation is ongoing.  However, the system is neither global nor harmonized, so careful attention is required to be sure that the new classification and labelling rules are applied correctly.

Challenges for compliance

It is important to note that although technically companies have until June 1, 2015 to classify their products, unlike the European Classification, Packaging and Labelling (CLP) regulation there is not a phased timeline differentiating between substances and mixtures (substances were classified well ahead of mixtures).  Under HAZCOM 2012 affected companies do not get the advantage of having updated classification for substances provided by suppliers to assist with the mixture classification.  Chances are they are they are also waiting on their suppliers, and as a result, in order to meet the deadline, companies must begin classifying their products now.

Supply chain issues can also come into play.  The unavailability of information required to classify products can be a large obstacle.  Companies often lack compositional information for their raw materials which is required to generate accurate classifications.  Often suppliers provide incomplete compositional information, for example formulations which contain primarily “confidential” or “proprietary” ingredients and which lack GHS information.

Furthermore, Safety Data Sheets (SDSs) generated for the EU CLP will not be adequate for HAZCOM 2012 as there are important differences in the approach.  Although both regulations are based on the UN Purple Book, there are additional points such as combustible liquids and explosive dust hazards not addressed in the EU. Also there are state regulations to take into account. Likewise, HAZCOM 2012 SDSs will not be suitable for use in other GHS countries such as China and Japan which have their own variations.  Fortunately, many countries will accept either HAZCOM 2012 or EU CLP SDSs as adequate, so long as the environmental sections of the SDSs are completed correctly.

Let us help

Anthesis-Caleb has considerable experience in identifying and classifying chemical substances, authoring SDSs and preparing labels for substances and preparations.  From our experience in the implementation of GHS through the CLP Regulation in Europe, we are able to bring substantial subject matter expertise to bear as Hazcom 2012 is rolled out.  The entire supply chain can be affected, and Anthesis-Caleb can provide our clients with a range of compliance consulting services including onsite training, workshops to build awareness of all requirements and the potential implications to your business, assistance with management of confidential chemical formulation information required for classification, product classification, and preparation of Safety Data Sheets and the required labels for chemical preparations.

Doug Lockwood is part of Anthesis' US operations and would be happy to speak to you should you have any Hazcom 2012 (or other) related challenges. Contact him at doug.lockwood@anthesisgroup.com