The new Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is now in effect. All chemicals shipped by manufacturers and distributors should now meet the OSHA GHS requirements and the packaging, marking and labeling requirements for hazardous materials transported in commerce in accordance with 49 CFR Parts 171-180, IATA, IMO, etc.
The transport regulations help guard against accidents while hazardous materials are in transit, usually short term and high-level hazards listed in US 49CFR Parts 100-185 based on the United Nations Model Regulations, and “hazardous wastes”. These regulations are not affected by the new GHS based HCS regulations.
Thile deciphering both GHS and transportation requirements for hazardous waste materials seem relatively simple, don’t be fooled. It is no small task to ensure that one doesn’t incorrectly impact the other. Consider that there are two, completely different sets of regulations for workplace HCS and dangerous goods (DG) transport; and, shippers must understand where one ends and the other begins.
There have been many conflicts concerning which regulation, or both, should be applied. In international shpments, often both transportation and GHS labeling may be required on the exterior of shipped containers. Further complicating issues are the instances where a shipped container is also the primary container and is required to display GHS hazard pictograms with associated hazards and precautionary statements etc. but do not require hazardous material transportation labeling. The ambiguity has potential for delays in transit.
Authorities say that if packages serve as both the shipping package and the final use container, they will probably require both proper transport labels, and the new HCS GHS hazard communication labels.
We know keeping your team on top of two sets of regulations is not easy; but, staying informed of current regulations will certainly assist in staying compliant and safe.