News Flash!  Sept 30, 2009, OSHA Proposes Implementation of Global Harmonization System for Hazardous Chemicals! 

The question was not whether OSHA would adopt the Global Harmonization System (GHS), it was when and how. 

We now have the start of the "when".  OSHA published a Notice of Proposed Rulemaking (NPR) in the Federal Register on Sept. 30, 2009.  The Public Comment period closed Dec. 29, 2009. 

OSHA officials at the Fall 2009 Society for Chemical Hazard Communication (SCHC, see www.schc.org for more info) stated publicly that it takees a minimum of 18 months for the legislation to go through the administrative steps necessary for Final Rule passage.  According to that, February 2012 we should start looking for the final regulations.

How Globally Harmonized Was OSHA's Proposed Rule?

While generally following the GHS Guidelines (16 section Safety Data Sheet (SDS), which replaces the existing Material Safety Data Sheet (MSDS), and with general alignment to the Hazard Classifications and Labeling standards, several changes were included in the proposed rule.

One of the most significant de-harmonizations of the OSHA proposed rule is that the OSHA proposal would make it mandatory that ALL precautionary statements appear on labels, not just the ones appropriate for the size container and manner of use.  This would make the US the only country that does NOT allow discretionary selection of the statements.

An example of the impact this could have on industry would be that all containers of Flammable Liquids would be required to carry statements including "Use spark proof tools" and "Use explosion-proof equipment".  While appopriate for large containers, the relevance to small containers is questionable.

Links: 

OSHA http://www.osha.gov/dsg/hazcom/global.html;

United Nations http://www.unece.org/trans/danger/publi/ghs/ghs_rev02/02files_e.html