GHS Review: Are You Moving Toward Compliance?

The deadline for training employees on the SDS and GHS labels was December 1, 2013, so you should already have done that.

The next deadline is June 1, 2015, when chemical manufacturers, importers, distributors must comply with all the requirements of the GHS rule (e.g., hazard classification, SDS format).

Then, by December 1, 2015, all shipments of chemical containers must include the GHS-compliant label (signal word, pictogram, hazard statement, and precautionary statement).

By June 1, 2016 all employers that use, handle, store chemicals must update alternative workplace labeling and hazard communication program as necessary and provide additional employee training for newly identified physical or health hazards.

Also by June 1, 2016, you must also update your written HazCom plan as necessary to reflect the new chemical label design and SDS format. The revised plan must also describe any changes to employee training requirements related to hazard classification and make chemical labels and SDSs understandable.

How GHS Changes HazCom

The following topics within HazCom contain the most significant GHS amendments:

• Hazard classification replaces the hazard determination
• Chemical label content and design
• Safety data sheet (SDS) replaces the material safety data sheet (MSDS)
• Employee training that covers new GHS-compliant labels and SDSs
• Written hazard communication plan

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Find out what you need to know about OSHA’s HazCom 2012, the revised hazard communication standard, which now incorporates elements of GHS. BLR is pleased to announce the availability a FREE Best Practices Report on GHS sponsored by Accuform Signs. To find out how to get your copy, click here.

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Labels

You must ensure that each container of hazardous chemicals in the workplace is labeled, tagged, or marked. If you purchase chemicals can rely on the labels provided by your suppliers.

The labels or other forms of warning must be legible, in English, and prominently displayed on the container, or readily available in the work area throughout each work shift. If you have employees who speak other languages, you may add the label information in their language, as long as the information is presented in English as well.

Neither you nor your employees may remove or deface existing labels on incoming containers of hazardous chemicals, unless the container is immediately marked with the required information.

Hazardous chemical containers must include either:

• The label shipped with the chemical container; or
• A product identifier and combination of words, pictures, or symbols that provide at least general information regarding the hazards of the chemicals and provide employees with the specific information about the physical and health hazards of the chemical.

You are not required to label:

• Pipes or piping systems
• Portable containers transferred from a labeled container intended only for the immediate use of the employee who performs the transfer

As an alternative to labeling all individual process containers, you can:

• Substitute various types of standard operating procedures, process sheets, batch tickets, blend tickets, and similar written materials for container labels on stationary process equipment if they contain the same information as the labels, and the written materials are readily accessible to employees in the work area throughout each work shift.
• Post signs or placards that convey the hazard information if there are a number of stationary containers within a work area that have similar contents and hazards.
• Use alternative labeling systems such as the National Fire Protection
• Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) as long as those systems are consistent with the GHS labeling system.

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Significant changes in OSHA’s hazard communication standard that impact more than 5 million workplaces will be phased in through June 1, 2016. To make sure your hazard communication program is in compliance with new GHS requirements we’re offering a FREE Best Practices Report. Find out more.

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All information supplied on the alternative labels must be consistent with the GHS label system; for example, there must be no conflicting hazard statement and pictogram.

If you become aware of any significant new information about the hazards of a chemical, you must revise the labels for the chemical within 6 months of becoming aware of the new information.

Tomorrow, we’ll review GHS-related SDS and employee training guidelines.

HazCom 2012: What You Need to Know

In 2012, OSHA adopted elements of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS) into its revised hazard communication standard, or HazCom 2012.

HazCom 2012 includes new requirements affecting:

• Hazard classification
• Labels
• Safety data sheets
• Information and training

These significant changes that impact employers, as well as chemical manufacturers, importers, and distributors, will be phased in through June 1, 2016.

Find out what you need to know to about the new GHS requirements going forward with the FREE Best Practice Report Hazard Communication with GHS: What You Need to Know. You’ll learn about:

• Major requirements of HazCom 2012
• Compliance deadlines
• Labels, tags, and markings
• The new safety data sheet (SDS)
• Employee training requirements
• Best practices to help you during the transition to HazCom 2012
• FAQs about GHS

To access your FREE copy of Hazard Communication with GHS: What You Need to Know, click here.