Globally Harmonized System Changes to Safety Data Sheets for Pesticides: Frequently Asked Questions
This letter provides information about the Globally Harmonized System of Classification and Labeling of Chemicals (Globally Harmonized System), particularly regarding the signal word. At present, the adoption of the Globally Harmonized System does not create any additional enforcement responsibilities for County Agricultural Commissioners (CACs). The Occupational Safety and Health Administration (OSHA) is requiring employers to train employees about Globally Harmonized System elements by December 1, 2013.
What is the Globally Harmonized System?
The Globally Harmonized System is an international standard for defining chemical hazards, and communicating hazard information on product labels and Safety Data Sheets (SDS), formerly known as Material Safety Data Sheets (MSDS). To view the actual text of the System, visit: https://www.unece.org/trans/danger/publi/ghs/ghs_rev01/01files_e.html.
Will it affect Safety Data Sheets?
Yes. The Globally Harmonized System will modify the format and content of SDS’s. One factor driving change is that OSHA already has aligned its SDS standards with the Globally Harmonized System. Some workplaces already are receiving SDS’s that conform to the Globally Harmonized System, including:
- a specified 16-section format;
- use of only two signal words: either “danger” or “warning”;
- specified statements about hazards; and
- pictograms to help communicate hazards.
For more information about SDS format and content, see Section 4 (Hazard Communication) on the following website: https://www.osha.gov/dsg/hazcom/ghs.html.
Will the Globally Harmonized System affect pesticide product labels?
In the future, some registrants may revise some labels to include Globally Harmonized System elements. Nonetheless, for pesticide products that are registered federally by the U.S. Environmental Protection Agency (U.S. EPA), product labels must comply with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
Regarding adjuvants, which must be registered within California but do not require U.S. EPA registration, DPR’s Registration Branch will provide additional information in a forthcoming Notice.
Could the content of an SDS differ from the content of a pesticide label?
Yes. If the SDS for a pesticide product conforms to the Globally Harmonized System, elements such as the signal word or certain hazard statements could differ from the pesticide label. For example, some pesticide labels bear the signal word “Caution”, whereas SDS’s under the Globally Harmonized System use only two signal words, “Danger” or “Warning”.
Do County Agricultural Commissioners have any new enforcement responsibilities?
No. CACs should continue to enforce the hazard communication and training requirements in California Code of Regulations, title 3 (3CCR), sections 6723(b)(3) and 6724(b). When pesticide suppliers replace MSDS with SDS that conform to the Globally Harmonized System, employers with employee handlers need to obtain and maintain the new SDS for the pesticides they use. SDS are part of the requirements for hazard communication and annual handler training in 3CCR 6723(b)(3) and 6724(b).
As always, if you encounter a pesticide product that you believe is misbranded, report it to the Enforcement Branch Liaison assigned to your county. However, SDS’s that conform to the Globally Harmonized System should not be considered misbranding in most cases. The reason is, the U.S. Environmental Protection Agency (U.S. EPA) has:
- reiterated its policy that SDS’s are pesticide labeling only when the SDS actually accompanies the pesticide product, and
- provided a mechanism by which SDS’s that use the Globally Harmonized System format will not conflict with registered pesticide labeling.
For more information, see: https://www.epa.gov/PR_Notices/pr2012-1.pdf.
What are pesticide users required to do?
- Continue to follow product labels, laws and regulations, and CAC permit conditions.
- Train employees about the new SDS elements and format by December 1, 2013. This is a federal OSHA requirement, not a requirement that is enforced by either CAC’s or DPR. For guidance on the training that OSHA requires, see https://www.osha.gov/Publications/OSHA3642.pdf.
- Continue to comply with requirements for hazard communication and annual handler training, when applicable. As always, such training is required to include contents of Safety Data Sheets. When pesticide suppliers replace MSDS with SDS that conform to the Globally Harmonized System, employers with employee handlers need to obtain and maintain the new SDS for the pesticides they use. For more information, see 3CCR 6723(b)(3) and 6724(b).
When did the Globally Harmonized System take effect?
The final rule aligning OSHA’s hazard communication standards with the Globally Harmonized System became effective on May 25, 2012. For more information, see: https://www.osha.gov/FedReg_osha_pdf/FED20120326.pdf.
If you have questions, please contact the Enforcement Branch Liaison assigned to your county.
Sincerely,