Make Sure Your HazCom Employee Training Is GHS-Compliant

HazCom training must now include information about the new GHS format safety data sheet (SDS) and GHS-compliant labels.

Training on label elements must include information on the type of information employees would expect to see on the new labels, including:

  • Product identifier. This refers to how the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS (Identification).
  • Signal word. This is used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. There are only two signal words, “Danger” and “Warning.” Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. There will only be one signal word on the label no matter how many hazards a chemical may have. If one of the hazards warrants a “Danger” signal word and another warrants the signal word “Warning” then only “Danger” should appear on the label.
  • Pictogram. OSHA’s required pictograms must be in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame sufficiently wide enough to be clearly visible. A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label. OSHA has designated eight pictograms under this standard for application to a hazard category.

Meet the challenge of GHS-mandated HazCom compliance. BLR’s upcoming live webinar will provide a practical way to assure ongoing compliance with the training, labeling, and SDS requirements of the revised standard. Click here for details.

  • Hazard statement(s). describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.” All of the applicable hazard statements must appear on the label. Hazard statements may be combined where appropriate to reduce redundancies and improve readability. The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it.
  • Precautionary statement(s). This means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.
  • Name, address and phone number of the chemical manufacturer, distributor, or importer.

Employee training should also cover how employees might use labels in the workplace. For example:

  • Explain how information on the label can be used to ensure proper storage of hazardous chemicals.
  • Explain how the information on the label might be used to quickly locate information on first aid when needed by employees or emergency personnel.

Employees must also be trained in a general understanding of how label elements work together. For example:

  • Explain that where a chemical has multiple hazards, different pictograms are used to identify the various hazards. The employee should expect to see the appropriate pictogram for the corresponding hazard class.
  • Explain that when there are similar precautionary statements, the one providing the most protective information will be included on the label.

SDS Training

Training on the format of the SDS must include information on:

  • Standardized16-section format, including the type of information found in the various sections For example, the employee should be instructed that with the new format, Section 8 (Exposure Controls/Personal Protection) will always contain information about exposure limits, engineering controls and ways to protect yourself, including personal protective equipment.
  • How the information on the label is related to the SDS. For example, explain that the precautionary statements would be the same on the label and on the SDS.

Join us on July 24 for an in-depth webinar on new HazCom requirements and how to train employees who use both old MSDSs/labels and new SDSs and GHS-compliant labels. Learn More

Meet the GHS/HazCom Training Challenge

With the revised OSHA hazard communication standard in place, the challenge for EHS managers now lies in transitioning away from old HazCom programs to the new requirements, especially those for training on the new MSDS format and label regulations.

December 1, 2013 marked the date by which employees needed to be trained on how to read/understand GHS formatted SDSs and labels. The next big deadline is coming up on June 1, 2015, the date by which chemical manufacturers must complete the reclassification of their chemicals and update their safety data sheets. Many manufacturers are waiting until the deadline to do the work, which will exert considerable pressure on the downstream users of those chemicals, including employers who will likely see a large influx of data sheets at one time.

Transition periods are always tricky, especially for programs as complex as these. Moving forward at a steady and compliant pace will test the resources, and the patience, of the entire organization, and figuring out a clear path forward may seem daunting.

Get a jump on conquering the challenge by joining us on July 24 for an in-depth webinar. Our presenter, a seasoned EHS professional who has been intimately and actively following the hazard communication standard revision, will provide a practical way to assure ongoing compliance with the training, labeling, and MSDS requirements of the new standard.

You and your colleagues will learn:

  • An overview of the revised hazard communication standard with a focus on the new MSDS format, the new label requirements and training
  • Key dates you need to consider for management of MSDS and labels and resources available from OSHA and state agencies
  • The difference between the old MSD sheet and the new MSD sheet and old labels and new labels-side by side comparison
  • Proven strategies for training during the transition period, including how to move your old MSDS supported database to a database based on the new MSDS format
  • Successful ways to transition your old labels over to the new label format
  • How to decide if now is the time to implement an electronic based MSDS management system if your existing program is paper based
  • How OSHA (and many state counterparts) are enforcing the revised standard training, MSDS, and labeling requirements
  • How to identify and evaluate outside resources to help you develop a compliant revised hazard communication standard training program

About Your Speaker

Brad Harbaugh is editor of the Environmental Health and Safety Blog for MSDSonline—a leading provider of on-demand compliance solutions for managing chemicals, material safety data sheets (MSDSs), OSHA Recordkeeping, and other critical EH&S tasks. In addition to researching and reporting on current EH&S issues, Mr. Harbaugh is the creator of MSDSonline’s popular GHS Answer Center and GHS Webinar series.

A sought after speaker, he has presented at more than 100 national and Regional conferences on topics ranging from education to safety, including at events for NSC, ASSE, VPPPA and others. Mr. Harbaugh is a graduate of DePaul University and is currently attending the Kellstadt Graduate School of Business.

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