In 2012, the Occupational Safety and Health Administration (OSHA) integrated the Globally Harmonized System into the Hazard Communication Standard (GHS). Over time, there have been a number of revisions in the worldwide standards, impacting how products are labeled in different countries.
  
With the relative complexity of the GHS-based health hazard classification procedures that are now part of the OSHA hazard communication standard, the ink industry is seeing differences between identical input raw materials in terms of how they are classified. The question becomes how to address this issue.
  
“When OSHA integrated the Globally Harmonized System into the Hazard Communication Standard (GHS) in 2012, it used the current version of the GHS,” said George Fuchs, director, regulatory affairs and technology for the National Association of Printing Ink Manufacturers (NAPIM). “There have been a number of revisions to the GHS since that time. Many other jurisdictions, geographic areas utilize the most current GHS version. This can create inconsistencies and discrepancies primarily in health hazard classifications. Accordingly, ink manufactures selling into non-US markets need to be aware of these GHS health hazard classification differences and develop their safety data sheets accordingly.
 
“In the US, the SDSs and labels are intended for use by employees handling or potentially exposed to the materials. In other jurisdictions, SDSs and labels are intended for use by EHS professionals,” Fuchs noted. “This distinction has become increasingly problematic as the information conveyed on SDSs and labels has become more complex. This was one of the concerns raised when OSHA proposed GHS adoption. Ink manufacturers need to ensure that this complex toxicity information is provided to users in a form that can be read and understood by understood by untrained and non-technical users.”
  
“It has been a number of years since OSHA adopted the GHS principles,” Michael Gould of Rahn, RadTech North America’s EHS chair, said. “The compliance deadline was 2015. Over the last few years, we are finding most identical raw material classifications used in ink formulations are harmonized. In the event classifications are not harmonized, it is best practice for a company to conduct additional research to determine the most appropriate classification. For companies that don’t have the expertise, it is best practice to use the most conservative classification when determining the classification of their product containing the raw material.”
  
“I don’t have specific information about differences in labeling of chemicals other than to say, anecdotally, that there is almost no harmonization in labeling between Europe, North America, and Asia,” said David Wawer, executive director, Color Pigments Manufacturers Association, Inc. (CPMA). “Even in North America, the Canadian system being rolled out has significantly difference labeling requirements than the USA. Companies must scrutinize which region of the world their products are being sold in, and label the bags/boxes/totes/containers accordingly. The movement to GHS has resulted in higher supply chain costs.”
 
Duane Ness, director of EHS and regulatory compliance for INX International Ink Co., noted that differences do occur, although not often.
  
“As chemical manufacturers, it is our responsibility to properly and accurately classify our products,” Ness added. “That is our job as regulatory professionals; gather and understand classification data to properly classify our own products in order to reduce or eliminate health and safety risk for our employees and customers.
 
“Health hazard communications between US and EU are similar or the same,” Ness added. “The major differences between US and EU hazards communications are for environmental hazards (hazardous to the aquatic environment) and physical hazard recognition.”