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Pallet C e nt ral • July -Aug u st 2 0 24 39 "liquid," "physician or other licensed healthcare professional (PLHCP)," "released for shipment," and "solid." It includes revised denitions for "exposure" and "exposed," "hazardous chemical," and "physical hazard." !e hazard classications for a substance or mixture must consider the chemical's intrinsic properties, including any change in chemical physical form or chemical reaction products associated with known or reasonably anticipated uses or applications. !is may require manufacturers to better anticipate downstream chemical use. With respect to ammable gas hazard classication, there is a new hazard class (desensitized explosives) and new hazard categories (unstable gases and pyrophoric gases in the Flammable Gas category, and nonammable aerosols in the Aerosols class). !e rule also includes revised health hazard statements and precautionary statements depending on the chemical involved, and revisions to the terms "skin corrosion/irritation" and "serious eye damage/eye irritation" chapters of the hazard classes. As far as changes to Safety Data Sheets and labels, only certain products (aerosols, desensitized explosives, and ammable gases) will be impacted by the new classication criteria, but aected establishments must update those labels and SDSs (and downstream employers using or handling these products must update their training and documents accordingly). !e 2012 rule was the initial eort to adopt the Global Harmonization Standard—or GHS—and use that international guidance standard (developed by the United Nations with input from member countries) to enhance worker protections, comprehension of the hazards, and bring greater uniformity across US agencies including OSHA, the Mine Safety and Health Administration (MSHA), the Department of Transportation (DOT), and the Environmental Protection Agency (EPA). OSHA also stressed, in 2012, that adoption would bring the United States into "harmony" with our major trading partners in Canada, Mexico, and the EU. !e only problem was, by the time OSHA completed its rule in an arduous and lengthy process that resulted in adoption of the "3rd Revision" to GHS, the rest of the world had moved on to a later GHS version. So had DOT and EPA. !erefore, even within the US government, there was no alignment on which GHS version to use. For its part, MSHA decided not to adopt any GHS rule at all for mining, but it did recognize contractor programs that were compliant with the current OSHA requirements and included the requisite worker training. Pallet C e nt ral • July -Aug u st 2 0 24 39

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