The road to GHS: worker right-to-know in the 21st Century

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Notes

*The GHS proposed standard is, strictly speaking, an amended version of HazCom and the formal title of the proposal reflects that. However, the 2009 proposed standard is different in important ways from the 1983 HazCom, so that it is much more appropriate to refer to the new proposal—and the final version of the rule, when that appears—as GHS rather than HazCom.

† An industrial hygienist familiar with HazCom has noted, regarding the written programs, that: “…having a written program is one of the most important features of the standard…Employers never want to have requirements for any programs to be written. The problem of having canned written programs—and the failure to fully implement what is written—is a very real problem.” (Personal communication, Bill Kojola, October 7, 2011)