USA - GHS Status

The US has implemented the Third revised edition of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS3) in the workplace through the revised Hazard Communication Standard (29 CFR 1910.1200) (HAZCOM) issued by the Occupational Safety and Health Administration (OSHA) in 2012. The GHS was adopted on 1 June 2015 for classification of substances and mixtures.

A long-awaited final rule updating the Hazard Communication Standard (HCS) was released by the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) on May 20, 2024. The update incorporates the seventh revised edition of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) into OSHA's Hazard Communication Standard (HCS). The revised HCS regulation came into force on July 19, 2024. Manufacturers, importers, and distributors must comply with the new requirements by January 19, 2026 for substances and by July 19, 2027 for mixtures. 

Local Adaptation of GHS

The following GHS categories are not implemented in the USA (GHS 7):

• Acute Toxicity, Category 5

• Skin Corrosion/Irritation, Category 3

• Aspiration Hazard, Category 2

GHS Labelling

Like many other countries, the US also has its own GHS labelling requirements. The requirements are set by Paragraph (f)(1) of the Hazard Communication Standard and allocation of label elements can be found in Appendix C of the Standard. A hazardous chemical is correctly labelled if the label includes the following in English:

• Product identifier (the chemical name, code number, or batch number)

• Signal word

• Hazard statement(s)

• Pictogram(s) in the shape of a square set at a point and shall include a black hazard symbol on a white background with a red frame sufficiently wide to be clearly visible

• Precautionary statement(s) – (statements can be combined or unnecessary ones left out If necessary for the sake of readability and clear communication)

• Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.

The GHS 7 revision brings significant updates labelling requirements i.e. Specific guidelines for labels (such as pull-out, fold-back, and tag systems) for small containers.

There is no specified minimum size for the labels or pictograms in the US, but the text must be legible, sections separated, and elements must not overlap. Manufacturers or suppliers must put a GHS-compliant label on all primary chemical containers – in other words, the ones used for distribution.

The revised HAZCOM created a need to identify hazards not covered by the classes adopted from GHS or that the Occupational Safety and Health Administration (OSHA) did not adopt (e.g. pyrophoric gases, simple asphyxiants, and combustible dust). Therefore, OSHA created the Hazard Not Otherwise Classified (HNOC) definition to cover health or physical hazards for which the standard lists a hazard class, but whose effect either falls below the cut-off value/concentration limit of the hazard class or is under a GHS hazard category that has not been adopted by OSHA. There are no harmonized label elements for HNOCs. Therefore, HNOCs need not be addressed on an HAZCOM label. No signal word or pictogram has been designated for HNOCs, so none should be assigned to an HNOC hazard. The label preparer may add supplemental information regarding HNOC hazards as long as it does not undermine or cast doubt on the required label information.

Safety Data Sheet

The Hazard Communication Standard (HAZCOM) requires chemical manufacturers, distributors, and importers to provide standard 16-section GHS Safety Data Sheets (SDSs) in English for each hazardous chemical to downstream users to communicate information on these hazards. The requirements for the SDSs are listed in Paragraph (g) of HAZCOM. Section 12-15 are not required by OSHA since those areas are not under their jurisdiction. They must, however, be included if the SDS is to be consistent with GHS. Hazards Not Otherwise Classified (HNOC) need to be disclosed in section 2 of the SDS but are not required on a label.

The GHS 7 revision brings significant updates to Safety Data Sheets (SDS) with Sections 3, 9, 11 & 14.

GHS in Work-Environment

GHS3 is implemented in the workplace since 2015 through the the revised Hazard Communication Standard (29 CFR 1910.1200) (HAZCOM). The HAZCOM Standard requires chemical manufacturers and importers to to evaluate the hazards of the chemicals they produce or import and prepare labels and safety data sheets to convey the hazard information to their downstream customers. Furthermore, all employers with hazardous chemicals in their workplaces are required to have labels and safety data sheets for their exposed workers and train them to handle the chemicals appropriately.

Recently in May 2024, OSHA updated HCS to bring provisions in line with the seventh revised edition of the GHS. To complete any necessary updates to the hazard communication program, alternative workplace labelling, and additional employee training for newly discovered physical or health hazards as a result of the evaluation of substances and mixtures; employers need to comply with these provisions for substances by 20 July 2026 and for mixtures by 19 January 2028.

GHS in Transport

National transport of dangerous goods in the US is regulated by the Hazardous Materials Regulations (Title 49 CFR Parts 100-15). The regulations applicable to the transport of dangerous goods have been updated to reflect the 20th revised edition of the UN Model Regulations.