KYZEN GHS / HCS Compliance Update – US Markets
The Occupational Safety and Health Administration (OSHA) Hazardous Communication Standard (CFR 1910.1200) requires manufacturers of chemicals to classify and communicate any hazards of their products. OSHA has adopted significant changes to this standard to conform to the Global Harmonized System of Classification and Labeling of Chemicals (GHS-CLP). Compliance with all modified provisions of this final rule is required by June 1, 2015.
What is GHS?
GHS-CLP provides a framework designed to harmonize the different requirements in many countries for classifying hazardous substances and mixtures, labeling them, and creating appropriate hazard communication documentation for these materials. Under these new GHS regulations–
- Red-bordered hazard pictograms will replace conventional orange symbols;
- The name ‘Material Safety Data Sheet (MSDS)’ will change to ‘Safety Data Sheet (SDS);’
- Standard 16-section SDS format, which is the same as our current KYZEN MSDS format;
- Signal words, hazard and precautionary statements will replace risk and safety phrases
What is the impact of GHS to KYZEN?
All KYZEN products manufactured after June 1, 2015 will be labeled according to the new GHS standards, and will likewise ship with a Safety Data Sheet compliant to the revised standard.
OSHA mandates that product in stock, manufactured and labeled prior to the
June 1, 2015 deadline, may still be distributed until December 1, 2015, at which time all products will be required to have a GHS-compliant label and SDS. This means that until Dec. 1, KYZEN customers, distributors and product partners can expect to see both the old and new style labels as we work to clear inventory stock.
KYZEN product formulations, manufacturing specifications and quality control processes will not be affected by GHS implementation.
Frequently Asked Questions – SAFETY DATA SHEETS
Q. How are Kyzen products classified under the revised Globally Harmonized System (GHS) Classification, Labeling and Packaging (CLP) legislation?
A. Kyzen products are a proprietary blend of raw materials that make-up a final product. GHS-CLP legislation classifies all Kyzen products currently on the EU market as mixtures.
Q. The revised Safety Data Sheet I received for a product I have previously ordered from Kyzen includes hazard classifications that were not present before. Has your product formulation changed?
A. NO, product formulations have not changed. New hazards may be identified for a mixture, because of the application of GHS evaluation criteria and hazard definitions to the constituents, which was not previously required. Therefore, a product could have new hazard classifications, even when no changes to the product formulation have occurred.
Q. Why does Section 3 (Product Composition) of your Safety Data Sheet only partially list information on product ingredients, or is altogether blank?
A. Section Three of a product Safety Data Sheet is reserved only for the disclosure of components in the mixture which carry a hazard classification. If a product does not contain any hazardous components- this section will likewise be blank.
Q. Why does Section 3 (Product Composition) list a product ingredient as “Trade Secret Ingredient?”
A. To protect proprietary information, a chemical manufacturer may withhold the specific chemical identity, or the exact concentration of a specific substance in a mixture, from the safety data sheet, even if such chemical carries a hazard classification, if prescribed criteria are met. See 29 CFR §1910.1200(i) for full criteria.
Q. Does Kyzen offer a Safety Data Sheet which lists all product ingredients?
A. NO. KYZEN does not disclose the proprietary chemical names of non-hazardous product components on Safety Data Sheets; however, all relevant health and safety information is included in the applicable subsections within, including chemical and physical properties necessary for disposal and other environmental considerations.
Q. Why do the hazard classifications in Section 2 of the Safety Data Sheet not always match those listed in Section 14?
A. GHS classifies HEALTH & SAFETY hazards apart from TRANSPORTATION hazards. For example, a product could be classified as a skin corrosive, but not be regulated as corrosive for transportation.
Q. Will KYZEN offer replacement labels for unexpired product already in distribution or in the workplace?
A. YES, after December 31, 2015, when specifically requested by customer.