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OSHA and other U.S. agencies have been involved in a long-term project to negotiate a globally harmonized approach to defining hazards, and providing labels and safety data sheets for hazardous chemicals. The result is the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS was adopted by the United Nations, with an international goal of as many countries as possible adopting it by 2008.

OSHA incorporated the GHS into the Hazard Communication Standard (HCS) in March 2012. The result was more specific requirements for hazard classification, as well as standardized label components and a standard approach to conveying information on safety data sheets. The adoption has the potential to address some issues regarding accuracy and comprehensibility in the U.S., which will improve employee protection and facilitate international trade.

However, the GHS is a living document and has been updated several times since OSHA’s rulemaking. OSHA's rulemaking was based on the third edition of the GHS and the UN recently completed the sixth. Since OSHA updated the HCS several things have happened.  First, the GHS is a living document and to remain aligned OSHA should periodically update the HCS to maintain maximum benefits.  Secondly, since implementation of the new system. OSHA has realized certain requirements of the HCS that need to be addressed to minimize undue industry burden.