With the hazard communication standard already a regular fixture on OSHA’s most frequently cited standards list, it’s more important now than ever before to understand how GHS affects your hazard communication obligations.
It’s important to remember that your hazard communication requirements will not be reduced by the Globally Harmonized System (GHS); they will simply be modified to support the new system.
Though implementing GHS does not involve a total rewrite of the hazcom standard, there are still a lot of changes coming your way. Pretty much everyone who uses hazardous chemicals has some responsibility…but some more than others.
- Chemical manufacturers and importers have some work to do around re-authoring MSDS and turning them into safety data sheets (SDSs). They also have to rewrite labels and warnings to make them GHS compliant.
- Resellers and distributors need to get the new SDSs and labels and distribute them to customers.
- And, of course, employers have plenty to prepare for, too.
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Get Ready, Get Set
Here are 8 steps your organization can take during the phase-in period to prepare for full compliance with GHS:
- Have an hazard communication plan. Maintain a checklist of key plan components and review it annually.
- Inventory your on-site chemicals and make sure you have a complete library of MSDSs and SDSs as you get them.
- Prepare yourself for the eventual switchover from MSDS to SDS. If you’re still using paper, consider transitioning to electronic system.
- Make sure your alternative labeling system is GHS compliant.
- Start developing a training plan for your employees now. Have a plan and make sure employees are ready to read GHS compliant SDSs and labels.
- Stay current on OSHA, including federal, state and local requirements. Keep an eye on GHS, looking out for key dates that will have an impact on your plan. (Note: That’s where Safety.BLR.com can help. This would be a great time to check it out!)
- Request GHS-compliant SDSs from your chemical vendors. Talk to your chemical suppliers and ask about their plans to transition to GHS. Make sure your staff is on the lookout for SDSs with new shipments.
- Stay SARA compliant. Update local and state emergency response agencies when new chemical hazard information becomes available. (SARA is the Superfund Amendments and Reauthorization Act, which requires facilities who are subject to OSHA’s hazardous chemical requirements to submit (M)SDSs or a hazardous chemical list to local and state authorities.)
By following these steps, you’ll be well on your way to preparing for the new requirements.
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Stay on Top of Developments
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We’re pretty excited about Safety.BLR.com and all of its enhancements, and we’re eager for you to experience it, too. That’s why we’ve created a complimentary site tour, available here. It takes just 5 minutes.
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