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GHS Implementation by Other United States Agencies

Implementation of GHS

In the U.S., EPA and three other key Federal agencies of government have regulations that would be affected by adoption of GHS. The other agencies are in various stages of planning for and implementing GHS.

The Department of Labor’s Occupational Safety and Health Administration (OSHA): OSHA has principal responsibility for regulating classification, labeling, and material safety data sheets required for chemicals in the workplace. OSHA requested comments on an Advance Notice of Proposed Rulemaking in September 2006 and has identified GHS as a priority rule-making activity. The next major milestone is the development of an economic analysis to support a proposed rule.  The agency has analyzed comments and is in the process of writing a Notice of Proposed Rulemaking.

The Department of Transportation (DOT):  DOT regulates chemicals in the transport sector. DOT has modified its regulations to incorporate most elements of the GHS that affect its programs, including physical hazards and the most severe categories of acute toxicity.  DOT plans to implement changes related to environmentally hazardous substances (aquatic toxicity) in line with the adoption of such changes by the International Maritime Organization, which is anticipated in January 2009.  

The Consumer Product Safety Commission (CPSC): CPSC has jurisdiction over more than 15,000 kinds of consumer products used in and around the home, in sports, recreation, and schools, including non-pesticide household chemicals. CPSC staff is completing a comparison of agency regulations and guidelines under the Federal Hazardous Substances Act to the GHS.  This review will determine which sections of the GHS might be considered for implementation, as well as whether statutory or regulatory changes would be necessary for eventual implementation

Interagency Coordination: The four core agencies (EPA, OSHA, DOT and CPSC) formed an Interagency Working Group on Harmonization to coordinate U.S. government participation in GHS activities and negotiations. The State Department also participates in the working group whenever international issues are under consideration, and a larger group involving other U.S. agencies may also become involved when issues potentially relevant to their programs are addressed. In addition to developing common positions for international meetings, the interagency group also provides a forum for the agencies to share drafts of documents for comment, exchange information, and discuss areas of mutual interest and concern.

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