Countdown to GHS compliance

OSHA’s revised Hazard Communication Standard is one of the most sweeping regulations the agency has issued in recent years, and compliance deadlines are approaching.

Published in March 2012, the final rule incorporates the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals, commonly known as GHS. The idea behind GHS is to make hazard warnings and labels found on products easier for workers to understand.

The requirements in OSHA’s updated standard will take effect in several phases. The first comes up later this year: All workers who come in contact with hazardous chemicals must be trained by Dec. 1 on the new requirements of the revised standard.

Specifically, employees must be trained on the new format of Safety Data Sheets (formerly known as Material Safety Data Sheets) and new labels, which include pictograms and signal words.

Although the compliance date is a few months away, it is best to begin training employees on the new requirements immediately, safety professional Daniel Levine notes.

“Waiting until the last minute is probably not going to help,” said Levine, president of Monroe Township, NJ-based consulting firm Product Safety Solutions. “People are starting to use these symbols now.”

Training requirements

To be clear, the requirement to train employees on hazard communication is not new, said Michelle Baker, product stewardship manager for Louisville, KY-based Zeon Chemicals. The new compliance date is for bringing employees up to speed on changes to the standard, and is in addition to the training employers already should have been conducting.

“Employers should have always been training their employees,” she said. “They always should have been able to recognize the hazards of the chemical with which they work. That requirement is not new and it hasn’t changed.”

The training should be fairly straightforward and not difficult for employers to present, Levine said, as OSHA has outlined what should be included.

However, according to Baker, problems could arise if workers have not been previously trained on hazcom because they likely will not understand the basics of chemical hazards, labels and SDSs. Training on the changes may then become more difficult, she said, because “you’re adding something new to what already may be confusing.”

For employers with an established hazcom training program, Baker suggested reviewing that program as the new elements from the revised standard are incorporated.

Labels

Employers must make SDSs available to employees for review, but employees are not required to look at them. However, the new labels are going to be on every container with hazardous materials, and employees will undoubtedly encounter them – if they have not already. Although manufacturers and distributors do not have to adhere to the hazcom standard’s new labeling and SDS requirements until 2015, they can begin following them now, said Levine, who recommended employers emphasize the label aspect of employee training.

According to OSHA, employees can expect to see the following on the new labels:

Product identifier. This can include information such as the name of the chemical and/or a code or batch number. This identifier must be identical to Section 1 of the SDS.

Signal word. This indicates the severity of the hazards, using the words “Danger” or “Warning.” “Danger” is for severe hazards, while “Warning” is for less severe hazards. Only one of these signal words will appear on the label, regardless of the number of hazards a chemical may pose.

Pictograms. Perhaps the most visible change to the labels is that every chemical is required to have a diamond shape with a symbol inside that represents a specific hazard category. Eight mandatory pictograms cover everything from health hazards and flammability to corrosions and explosions.

A ninth pictogram, dealing with environment, is not mandated by OSHA, but Levine recommended employees be trained because they should know what it means in case they come across it.

Hazard statement. This describes the nature of the hazards. All hazard statements of a chemical must be listed on the label, including a description of what adverse health effects the chemical can cause.

Precautionary statement. This is a phrase describing recommended measures to either minimize or prevent the adverse effects from the chemical due to exposure or improper storage.

Supplier information. The name, address and phone number of the chemical’s manufacturer, distributor or importer is included on the label.