The true cost of compliance with the GHS ruling may be more than $100 million.
The US' Occupational Safety and Health Administration (OSHA) estimates that the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)ruling will represent about 27% of compliance costs for the chemical manufacturing industry.
The OSHA aligned its Hazard Communication Standard with the United Nations' GHS in March 2012 to ensure chemical safety in the workplace. Its objective is to make information about the identities and hazards of the chemicals available and understandable to workers. Europe has a similarly aligned CLP standard.
Implementing the GHS ruling may mean the US lubricants industry will have to reclassify their mixtures or undertake specific testing.
Employee training in new labelling and safety data sheet formatting must be completed by the 1 December 2013 deadline and must include the differences between chemical and physical hazards and new labeling requirements. This incorporates pictograms, signal words, hazard statements and precautionary statements that will be used.
The alignment has implications for other US federal agencies which are either already implementing, or planning to implement the new rules, including The Environmental Protection Agency (EPA which is updating the 1976 Toxic Substances Control Act; The Consumer Product Safety Commission and The Department of Transportation.
Unlike Europe, where manufacturers have to prove their substances are safe, the EPA is empowered to make the judgement. The agency is currrently working in five areas: chemical action plans, dealing with confidential business information, chemical data reporting, chemical prioritization and risk assessment.
The EPA is also using the rule changes to develop more current and robust data. It is set to change testing requirements and has already withdrawn confidential business information protection for thousands of products.