• GHS Compliance by December 1, 2013: Are you Ready?

    GHS Compliant

    On March 26, 2012 the Federal Register published the final rule, moving OSHA’s existing Hazard Communication Standard to the Globally Harmonized System of Classification and Labeling of Chemicals; also known as GHS.

    GHS provides a standardized approach, including detailed criteria for determining what hazardous effects a chemical poses, ultimately improving the quality and consistency of hazard information in the workplace. This will enhance both employer and worker comprehension of the hazards, which will help to ensure appropriate handling and safe use of workplace chemicals.

    Safety Data Sheets Reformatting

    For most employers, those that are the end users of chemicals and not the manufacturers, the changes will be minimal. The biggest changes they will see will be the reformatting of SDS (formerly known as MSDS) and container labels that will contain more detailed information than what has been seen in the past.

    The Safety Data Sheets (SDSs) (formerly MSDSs or Material Safety Data Sheets) requirements establish an order of information that is standardized. The harmonized format of the safety data sheets will enable employers, workers, health professionals, and emergency responders to access the information more efficiently and effectively, thus increasing their utility. The information contained in the SDS is largely the same as the MSDS, except now the SDSs are required to be presented in a consistent user-friendly, 16-section format.

    GHS Standardized Labeling

    Labels have primarily served as the immediate means to communicate hazards to the end user. GHS requires standardized label elements assigned by hazard class and category. Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard. Alternative labeling systems such as the (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers; however, the information supplied on these labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms. In other words, these alternative labeling systems cannot be used alone, as the sole means to communicate the chemical information to the user.

    GHS will be phased in over the next few years, but the most immediate compliance date for employers is December 1, 2013. OSHA is requiring that employees be trained on the new label elements (i.e., pictograms, hazard statements, precautionary statements, and signal words) and SDS format. This training is not required to address the specific hazards of the chemicals, or the protective measures. Employees will have already been trained on hazards and protective measures under the existing hazard communication requirements, but they will not have had training on the new label elements and SDS format, nor have learned how this information is to be used in their workplaces. Completion of such training by December 1, 2013 will help to ensure they can use the new documents effectively when they begin to arrive in their workplaces.

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    Doug Miller About the Author
    Douglas D. Miller is the President of Occupational Safety Consultants, which was created in 2001. Doug has been involved in safety and health for over 15 years in various industries, including construction, maritime and general industry.For the past 13 years, Doug has taught for the Region II OSHA Education Centers and currently serves as course chairperson for 10 different courses, including the OSHA 500 and OSHA 501, and Construction and General Industry Train-the-Trainer programs.

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