The final deadline for the Occupational Safety and Health Administration’s (OSHA) phased-in compliance approach to implementing the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is around the corner—just about 1 month away. This is the deadline that affects all employers covered by OSHA’s Hazard Communication Standard (HCS). Is your organization ready? Here’s a breakdown of what you must have in place.
By June 1, 2016—yes, about 1 month away—all employers must have completed any necessary updates to their hazard communication programs, including workplace labeling procedures. Additionally, all affected employees must be trained on any new hazards identified during the manufacturers’, distributors’, or importers’ chemical reclassification process.
Note. Employers were required to train workers on the GHS labels’ elements and the new safety data sheet format (SDS) by December 1, 2013.
What You Don’t Need to Do
Employers that store and use chemicals but do not produce or import them do not have to comply with the requirement to evaluate and determine the hazards of those chemicals; employers will receive that information from the manufacturer or importer. “Use” in the context of the HCS means to package, handle, react (such as introduce into a process), or transfer.
What You Need to Do: Written Hazard Communication Program
By June 1, 2016, all employers must update existing written hazard communication plans 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 must make chemical labels and SDSs understandable.
What You Need to Do: Container Labeling
Under the GHS rules, employers must have a workplace labeling system in place by June 1, 2016, that is consistent with the GHS labeling system.
Shipped containers. Employers are responsible for maintaining labels on containers they receive so that the labels are legible and the pertinent information, such as hazards and directions for use, are not defaced or removed in any way. Employers are not responsible for updating labels on shipped containers even if the shipped containers are not GHS-compliant. However, employers must relabel containers if the labels are removed or defaced. If you become aware of newly-identified hazards in your workplace that are not disclosed on the label, you must ensure that your workers are aware of the hazards.
Secondary containers. You have the option of creating your own secondary labels specific to your workplace. If you have a workplace system that complies with the pre-GHS HCS requirements, you may continue to use this system instead of the label from a manufacturer, importer, or distributer as long as your workers have immediate access to all the information about the hazards of the chemical. Workplace labels must be in English, but other languages may be added if applicable. You may also add additional instructional symbols not included in OSHA’s GHS pictograms—for example, a person with goggles to indicate that goggles must be worn while handling a given chemical.
If you choose to use the GHS pictograms found at 29 CFR 1910.1200 Appendix C for your workplace labels, the pictograms may have a black border instead of the red border required for labels for containers that are shipped.
If you choose to use an alternative label system, 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.
Confused about your GHS compliance obligations? Safety.BLR.com® has a GHS and Hazard Communication Resource Center dedicated to helping access all the tips, tools, and training you need to be GHS-compliant.