The implementation of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) will affect over 43 million employees, handling nearly one million different hazardous chemicals across five million workplaces in the U.S. Chemical production is a $400 billion industry in the U.S. and $1.7 trillion worldwide, and with GHS, it is expected that injuries will be reduced by 500 and deaths will be reduced by 43 each year. That’s a big deal – even from an inventory management perspective.
GHS is an update to OSHA’s Hazard Communication Standard 29CFR 1910.1200. The goal is to harmonize safety information so when hazardous chemicals are handled in the workplace, there will be consistent hazard information regardless of if that chemical comes from the U.S., Canada, Latin America, Europe or any other country. This is a safety enhancement from the varying label formats that are used today (see below).
GHS standardizes label information (six key elements), pictograms (9 graphics) and the companion Safety Data Sheets (16 categories in a specified order). The heavy lifting falls on chemical manufacturers to change the labels on their primary containers by June 1, 2015. So what does that mean for the rest of us who receive, store and use chemicals in the workplace every day?
GHS To-Do List (Mid Year 2014)
Know the Deadlines – GHS is a time-phased implementation. Make sure your organization and key individuals understand the deadlines and have goals in place to meet them. Specific OSHA plan states may have deadlines slightly different than the federal deadline. The federal requirements include:
June 1, 2015 – Chemical manufacturers reclassify chemicals, Safety Data Sheets (SDS) and labels in GHS format
December 1, 2015 – Distributors only send products with updated SDS and labels
June 1, 2016 – Employer full compliance deadline
2. Train and Re-Train – Your employees need to understand hazard labels, pictograms and the information found on SDS, and employees that handle chemicals need to be trained and quizzed on this information. If you missed the December 1, 2013, training deadline, there’s no better time to start than now. Use available DVD courses, posters, wallet cards and hand books to supplement and reinforce training information.
3. Identify Your Chemical Inventory – Take an inventory of your chemicals and know which chemicals have transitioned to the new labels and SDS. Purchase SDS binders and wall-mount centers and keep separate binders of MSDS and SDS sheets to help track your transition. Talk to your suppliers about their transition plans.
4. Prepare to Label Secondary Containers – OSHA recommends replicating the primary label for your workplace secondary containers. The only exception is when the chemical is consumed or used up within the work shift and the chemical is under the exclusive control of the employee using the chemical. For facilities needing only a few secondary labels or thousands of labels, talk to your label supplier to get pre-printed labels. If you’re somewhere in between, consider purchasing a printer to print-your-own – it’s likely to be more cost effective. Look for printer suppliers with GHS software and templates to make this process quick and easy.
5. Audit the Process & Update the Policy – Document the training, stress test the process, identify where the SDS information is located, including a back-up copy, document the process for secondary labeling and update your written hazard communication program.
At its core, GHS is a straightforward regulation that aims to equip us and our employees with an understanding of the hazards associated with the chemicals we deal with, how to avoid a bad situation and where to get information if that occurs. In 2013, there were 6,156 violations of the Federal HazCom Regulation in the U.S., and too many injuries and deaths related to hazardous chemicals. The famous line from the 1967 movie “Cool Hand Luke” still strikes a chord with people and companies all over the world – “What we’ve got here is failure to communicate.” And when it’s a life or death situation, that’s when consistent communication matters most.
As is customary with new regulations, many implementation questions surface around specific label applications, exceptions, what’s covered, what’s not and more. These frequently asked questions might even be the subject of a future blog.
– Thomas Smith is the Regional Marketing Specialist for Brady Corporation Worldwide. He has over 20 years of experience developing safety, identification and productivity solutions for commercial, industrial and construction markets.
This information was written, published, and released by Brady Corporation Worldwide.
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