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New Hazard Communication Requirements Coming Soon

FSMA, FDA, PM10, MSDS, VOC, EPA, OSHA…when and where do the acronyms stop? Well, unfortunately, we don’t know, but the next two acronyms that everyone should have learned by Dec. 1 are GHS and SDS. The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is a system for standardizing and harmonizing the classification and labelling of chemicals. In other words, it is an international plan that will make how we classify, label and communicate chemical hazards easier and more uniform across the board.

While many countries already had regulatory systems in place for these types of requirements, the differences in their programs were significant enough to require multiple classifications, labels and safety data sheets for the same product when marketed in different countries, or even in the same country when parts of the life cycle are covered by different regulatory authorities.

This led to inconsistent protection for those potentially exposed to the chemicals, as well as creating extensive regulatory burdens on companies producing chemicals.

For example, in the United States there are requirements for classification and labelling of chemicals for the Consumer Product Safety Commission (CPSC), Department of Trans-portation (DOT), Environmental Protection Agency (EPA), and Occupational Safety and Health Administration (OSHA). Yes, I know…more acronyms.

The GHS was created to resolve these conflicts. The first compliance date was Dec. 1, 2013. By that time employers must have trained their workers on the new label elements and the safety data sheet (SDS) format. The new SDS will replace the old material safety data sheet or MSDS. This training is needed early in the transition process since workers are already beginning to see the new labels and SDSs on the chemicals in their workplace.

To ensure employees have the information they need to better protect themselves from chemical hazards in the workplace during the transition period, it is critical that employees understand the new label and SDS formats.

I know what you are thinking. So why do I, as a cotton farmer or ginner, need to worry about this? Because, all employers are required to have a written “hazard communication program” in place. OSHA regulations require all employers to provide information to their employees about the hazardous substances to which they may be exposed, by means of a hazard communication program, labels and other forms of warning, material safety data sheets, and information and training.

Whether it is pesticides, fumigants, cleaning chemicals or lubricants, farms, hullers and processors, all have chemicals and they need to ensure they have a hazard communication program in place and are adequately conveying the hazards. As the staff of the California Cotton Ginners and Growers Associations and the Western Agricultural Processors Association (WAPA) visits our members and clients, this is one of the critical elements we look for in our on-site inspections and visits. We encourage all cotton growers and ginners to have their Hazard Communication programs reviewed and updated.

Roger Isom of the California Cotton Ginners and Growers Association contributed this report. Contact him at

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