Looking at the GHS: How to be Prepared
If not this month, at some point this quarter, we can expect to see OSHA’s final rule on aligning the Hazard Communication Standard (HCS) with the UN’s Globally Harmonized System of Classification and Labeling of Chemicals (GHS) published in the Federal Register. If you haven’t heard of it yet, the GHS is basically a way to align, or harmonize, the way chemical hazards are classified, labeled and communicated to others across all nations that participate with the GHS. The main benefit is that everyone involved in the life cycle of a chemical, from producer to consumer, and everyone in between, will be able to easily understand the hazards posed by the chemical, thus reducing accidents and illnesses and increasing overall safety. But what changes can be expected and how can you be prepared for them?
The first and most important step to take is to educate yourself. Hopefully, you’re already familiar with the requirements of the current HCS and only need to learn the differences between the two. The major differences lie in three areas:
- Chemical Classification
- Safety Data Sheets (SDS) and
Appendices A and B of the new standard describe in detail the classification system being used for health and physical hazards respectively. Chemicals will have a chemical class based on the health and physical hazards and also a chemical category, based on the types of hazards associated with that class. Hazard categories can be presented in either text or numerical form. For instance under the class Gases Under Pressure, the hazard categories are listed as compressed gas, liquefied gas, dissolved gas or refrigerated liquefied gas. On the other hand, under the class Flammable Liquids, hazard categories are in numerical order from 1-4, 1 being the most hazardous and 4 being the least. (Please note how this differs from the NFPA/HMIS numbering that many are used to where 1 is the least hazardous and 4 is the most.) Once manufacturers or importers have classified the chemical the next step is communication. Chemical hazards are communicated through Safety Data Sheets (SDS) and labels, created and provided by the manufacturer.
Safety Data Sheets
While the old Material Safety Data Sheet (MSDS) had to have 12 sections that could be organized in any way, the new SDS has 16 sections that must be presented in a specific order. As of right now, sections 12-15 (ecological information, disposal considerations, transport information, and regulatory information) are not mandatory as they do not fall under OSHA’s jurisdiction. We may see changes on this later as EPA and DOT regulations are aligned with the GHS.
Label requirements are very specific under the GHS. All labels are required to have the following parts: a product identifier (the name of the chemical as seen on the SDS), signal word (Warning or Danger), a hazard statement (i.e. fatal if swallowed, harmful if inhaled), a pictogram (one of eight standard symbols), and precautionary statements (special prevention, response, storage, and disposal considerations). This information must be provided for each hazard class and associated hazard category. While it is the job of the manufacturer to provide these labels, in the end it falls on the employer to ensure that the labels are available, legible, and prominently displayed. Not all retailers are required to have labels and SDS for chemicals they are not using themselves. If the vendor does not provide a SDS or label for the chemical, it is the employer’s responsibility to contact the manufacturer and obtain these documents.
It is imperative that all companies that keep hazardous chemicals on site, have a current Written Hazard Communication Program available, Safety Data Sheets readily available for all chemicals on site and labels prominently displayed on chemical containers. Even more important? Understanding the information contained in the written program, SDS, and on the label and making sure employees understand it too. And this brings us to training.
OSHA is requiring that all employees be trained on the changes happening with the GHS/HCS within 2 years of the final rule being published in the federal register. However, the time to start training is as soon as employees begin to see changes taking place and are affected as a result of the new regulation. Employees must be trained on Safety Data Sheets, labels, and the specific hazards they can reasonably be expected to encounter as a result of their job responsibilities.
This article is not meant to be comprehensive. Think of it more as a way to get your foot in the door. It’s a short synopsis so you have some idea of what you’re getting into when you go to OSHA’s website and delve into all the very specific requirements of the GHS. The most important thing you can do to prepare for the GHS is to educate yourself and your employees.
This information is provided as a service to you by Compliance Consultants, Inc.