Implementation of the GHS is a dynamic process, thus its status needs to be regularly reviewed, completed and monitored on the basis of any new information made available.

For that reason, the secretariat has started to gather information from various sources, such as:

  • Reports from members of the GHS Sub-Committee or NGOs
  • Reports submitted to or issued by other United Nations organs, programs or specialized agencies (UNECE, UNITAR, IMO, ICAO, UNEP, WHO, ILO) or other intergovernmental organizations (European Commission, APEC), non-governmental organizations
  • Reports on various workshops, seminars, conferences and other events organized in relation with the implementation of the GHS.

The GHS is implemented by a number of international organizations, United Nations programs and specialized agencies related to chemical safety in the field of transport or the environment, occupational health and safety, pesticide management and prevention and treatment of poisoning. In order to achieve their goal, they develop, amend or revise their relevant international instruments.

Detailed information about the progress of the work in the different areas regarding the implementation of GHS by United States is given below.

Workplace
Focal point: Department of Labor: Occupational Safety and Health Administration (OSHA)
Main relevant legislation: Occupational Safety and Health Standards
GHS implementation milestones: On 26 March 2012 the revised Hazard Communication Standard (HCS) was published in the Federal Register.The revised HCS is in line with the third revised edition of the GHS. It will become effective on 25 May 2012 although it will not become mandatory until 1 June 2015. During this phase-in period, and to give industry enough time to produce labels and Safety Data Sheets (SDS) consistent with the revised provisions, employers will be allowed to use at their own discretion, the existing HCS, the revised one, or both.

Additional information and guidance is available at OSHA’s website
Transport of dangerous goods
GHS implementation status ImplementedFor international transport of dangerous goods, see Implementation through international legal instruments, recommendations, codes and guidelines

For national transport: the regulations applicable to the transport of dangerous goods (Title 49 of the Code of Federal Regulations) have been improved to present the 15th revised edition of the UN Model Regulations, with very few exceptions.
Focal point: Department of Transportation (DOT): Pipeline and Hazardous Materials Safety Administration (PHMSA)
Main relevant legislation: Hazardous Materials Regulations (Title 49 CFR Parts 100 -185)
Pesticides
Focal point: Focal point: Environmental Protection Agency (EPA): Pesticides Program ( Office of Prevention, Pesticides and Toxic Substances)
Main relevant legislation: Toxic Substances Control Act (TSCA)
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
Federal Food, Drug, and Cosmetic Act (FFDCA)
GHS implementation milestones: At first, the Environmental Protection Agency (EPA) described thinking on the potential application of the GHS to pesticide labels in a “White Paper” and called for public comment on their plans through a notice published in the U.S. Federal Register. In October 2006, the EPA held a public meeting with stakeholders to review the issues raised in the White Paper and comments, and to ask for additional information on possible ways forward. EPA is examining following steps based on the information received, seeking additional data, and exploring possibilities for GHS pilot activities. In 2007, EPA revised its communications materials and overhauled its GHS web site.
Consumer Products
Focal point: Consumer Product Safety Commission (CPSC)
Main relevant legislation: Consumer Product Safety Act
Federal Hazardous Substances Act
GHS implementation milestones In 2007, CPSC made a comparison between selected parts of the Federal Hazardous Substances Act (FHSA) regulatory requirements to the Globally Harmonized System (GHS) for classification and labeling. This comparison defined several of the technical differences between the FHSA and GHS. A preliminary legal feasibility assessment was also conducted to evaluate what, if any, changes would be necessary to the FHSA. As the staff work pointed out, a more complete technical comparison is needed. In 2008, CPSC started a contract to fulfill a side-by side comparison of the FHSA and the GHS. The scope of this review is to define which sections of the GHS may be considered for implementation, as well as whether statutory or regulatory changes would be necessary for eventual implementation.