How is GHS implemented
in the United States?

In the United States, the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals, commonly known as GHS, is adapted through the Hazard Communication Standard (HCS or Hazcom). This standard introduces the classification and communication systems for hazardous chemicals in accordance with the GHS in the United States.

What is Hazcom Standard?

• The HCS or Hazcom standard is the adaptation of the GHS Revision 7 in the United States. Importantly, latest updates of Hazcom incorporate some elements of the GHS Rev. 8.
• The Hazcom standard is recorded in the Federal Register 17574 (29 CFR Parts 1910, 1915, and 1926) and has been mandatory in the United States since June 2015.
• • The latest update to the Hazcom standard includes changes such as improved labels and safety data sheets (SDS) and the incorporation of new hazard classes and classification procedures, among others. These changes will be implemented in a two-phase process, with the first phase applying to chemical substances (January 19, 2026) and the second phase including chemical mixtures (July 19, 2027).
• The main official body responsible for the GHS adaptation is the Occupational Safety and Health Administration (OSHA) of the Department of Labor.
• Some chemicals, such as pesticides, cosmetics, or products intended for general consumer use covered under the Consumer Product Safety Commission (CPSC), are regulated by other specific Federal Laws.

What are the most relevant points of Hazcom?

• Safety Data Sheets must be written in English.
• SDS must follow the 16-section structure of the GHS.
• It includes only two types of hazards for classification and labeling purposes: physical hazards and health hazards.
• The following hazards are not covered by Hazcom: acute toxicity, category 5; skin corrosion/irritation, category 3; and aspiration hazard, category 2.
  • o On the other hand, the following hazard classes and categories are included: Hazards Not Otherwise Classified (HNOC), combustible dust, pyrophoric gases, and simple asphyxiants.
• The labeling of hazardous products requires clearly labeling containers with product identification, hazard pictogram(s), signal word, hazard statements, appropriate precautionary statements, and supplementary information, along with the supplier information of the substance or mixture.
  • Additionally, supplementary information such as HNOC or the concentration of ingredients with unknown acute toxicity (when their concentration is ≥1%), among others, can be voluntarily added.

What other chemical regulatory requirements apply in the United States?

• To manufacture or import chemicals in the US all substances must be listed in the Toxic Substances Control Act (TSCA) inventory, be exempt, or be regulated by other US laws. The TSCA is maintained by the US Environmental Protection Agency (EPA).
• The National Fire Protection Association (NFPA) is responsible for the NFPA 704 Standard, which introduces the "hazardous materials diamond" used to communicate hazards in emergency situations.
• The Hazardous Materials Identification System (HMIS) is a numerical hazard classification that incorporates the use of color-coded labels developed by the American Coatings Association (ACA). The HMIS color bar, which is similar to the fire diamond created by the NFPA, is used to communicate hazards more extensively.
  • Both NFPA 704 and HMIS are not mandatory and can be used in both labeling and SDS to provide supplementary information as long as they do not conflict with HazCom requirements.
• Volatile organic compounds (VOC) in the US are governed by various regulations. The most important is the table of limits provided by the California Air Resources Board (CARB), which sets maximum limits for VOC.
  • Additionally, other regulations to consider depending on the place of commercialization are the South Coast Management Air District (AQMD), Clean Air Act (CAA, which depends on the EPA), Ozone Transport Commission Rules (OTC), and Lake Michigan Air Directors Consortium (LADCO).
• Proposition 65 requires companies to notify the state of California about exposures to chemicals that may cause cancer, birth defects, or reproductive harm.
• Consumer Product Safety Act (CPSA) and the Federal Hazardous Substances Act (FHSA).
• The EPA also regulates pesticides at the national level under the authority of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and other laws.
• The Federal Hazardous Substances Act or FHSA is fundamental for regulating the safety and labeling of detergent products.
• Cosmetic products are regulated through the Federal Food, Drug, and Cosmetic Act.

To ensure compliance with legislation it is important to have an effective tool.

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