GHS: The look of things to come

Employers and employees will notice a different look to chemical labels in only a matter of months – if they haven’t already.

Beginning June 1, chemical manufacturers, importers and employers must ensure all chemicals are shipped out with new labels and Safety Data Sheets that comply with provisions in OSHA’s updated Hazard Communication Standard.

In 2012, OSHA finalized a rule incorporating into its hazcom standard the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals, also known as GHS. The agency’s new standard requires hazard warnings and labels found on chemical products to be easier for workers to understand, allowing them to take appropriate precautions to stay safe.

The rule specifies the format of both the chemical product labels and SDSs (formerly known as Material Safety Data Sheets), and requires standardized pictograms representing the type of hazards the product may pose.

Some manufacturers may have already begun sending out products with compliant labels and SDSs, and experts believe many more will do so as the June 1 compliance date draws near.

“I think we’re going to see the changes come very quickly,” said Denese Deeds, an industrial hygienist with Shelton, CT-based Industrial Health & Safety Consultants Inc.

None of these new elements should be a surprise to workers. Employers were required to have trained all employees on the new label and SDS format by Dec. 1, 2013. But employers’ obligations do not end with worker training.

Retraining

Employees may not fully understand the labeling and SDS changes until they start seeing them on the specific chemicals they use.

“If you don’t have those SDSs as a practical example for workers to learn from, then the training is not effective,” said Susan Ripple, a Michigan-based consultant.

When the new SDSs and labels start coming in, Ripple recommends that employers provide refresher training for workers. Deeds points out that although most employees likely will understand the hazard warnings required under the new standard, not all of the pictograms are intuitive. The more training employees receive, the more effective the new labels will be at conveying information, she said.

Ripple suggests testing workers on their knowledge of the labels. Do this by running through the pictograms, the health phrases and hazard categories with employees to ensure they know how to interpret that information.

Employers who want to be proactive can contact their chemical manufacturer about SDSs before the June 1 deadline. “It’s good to know sooner rather than later,” said Angela Wutz, assistant general manager of product regulatory services for Pace Analytical Services in Minneapolis.

However, providing updated SDSs before June 1 is not required.

Worth noting is that manufacturers may not be violating the law if they fail to provide updated SDSs by the June 1 deadline. Some labeling and packaging elements for chemicals from large manufacturers have a long lead ?time – perhaps as much as six months, according to Wutz. So if a manufacturer shipped out a large order on May 31, updated labeling elements technically do not need to be provided until the next time a shipment is made.

Further, some manufacturers creating chemical mixtures may be waiting for updated SDSs from their own suppliers. If these manufacturers do not have the updated SDSs on the raw substances, they cannot create their own SDSs and labels on mixtures for customers.

New hazards

Along with conducting refresher training, employers receiving new SDSs should update their hazard communication binders or SDS books. Additionally, they should take the opportunity to review whether their hazard prevention program needs updating, according to Wutz.

“Employers are going to want to look at the incoming Safety Data Sheets and labels … to make sure their precautionary measures are still in line with what their vendors are recommending,” she said.

This is not a new recommendation – employers should always review their chemical safety policy whenever their vendor updates the SDSs, Wutz said.

Employers may find that a product they have been using for years suddenly has a new hazard warning accompanying the new labeling. Part of this is due to new classification criteria for substances and more specific guidelines on which warnings have to be included on labels. This does not mean the hazard is new.

“It doesn’t change the actual physiological response to the chemical. It changes our awareness,” Deeds said.

Everything will be in plain English, too, which could change how employers and employees perceive hazards. An SDS stating that a certain substance may cause gynecomastia might not raise an eyebrow, but saying the substance may cause breast cancer in men could get a different reaction.

“You might get out there and mitigate that risk pretty darn quick,” Ripple said.

Upcoming deadlines, no delay

The final compliance deadline under the new hazcom rule is June 1, 2016. On that date, employers’ workplace signage, label warnings and hazard communication programs must be updated. If any new physical or health hazards are identified for products that are being used, employers must train employees on those hazards by June 1, 2016.

Although some manufacturers are struggling with getting the new labels and SDSs out the door, experts who spoke with Safety+Health warned that OSHA likely will not delay enforcement of the updated standard. Employers should prepare by collecting the new SDSs (when available), reviewing their program, and making any appropriate changes based on new hazard information.