OSHA Adopts GHS -- Now What?

Pictograms are just one of the reasons employers should consider training employees on GHS formats well before the December 2013 deadline.

• By Glenn D. Trout
• Jun 01, 2012

In March, OSHA revised the Hazard Communication Standard (HCS, HazCom) to align with the Globally Harmonized System (GHS). OSHA is calling the revised standard HazCom 2012. One hopes all affected manufacturers, distributors, and employers are aware by now that a change has taken place and have assigned personnel to manage their transitions to HazCom 2012.

Background
GHS was developed by the United Nations as a global approach to classifying hazardous chemicals and communicating those hazards via labels and safety data sheets. OSHA's alignment of the HCS with GHS brings changes for everyone covered by the HCS. Changes include subdividing of physical and health hazard classes into sub-categories based upon severity, as well as new formats for safety data sheets and labels.

To comply, manufacturers and distributors must reclassify their chemicals and provide GHS-formatted safety data sheets and labels to downstream users. Employers must train their employees on GHS and make any necessary update to their hazard programs and workplace labeling strategies. Bottom line: Manufacturers, distributors, and employers have work ahead of them to bring their organizations into compliance with the revised standard. But where should companies start? One way of figuring out the next the step is to consider the four key deadlines for compliance outlined in HazCom 2012.

First HazCom 2012 Deadline: Dec. 1, 2013 (Employers)
By this date, employers must train their employees on how to read GHS-formatted safety data sheets and labels. OSHA makes this the first priority because GHS-formatted documents are already making their way into U.S. workplaces and can be very different from what workers are used to seeing. For instance, a compliant HazCom 2012 shipping label has six mandatory elements:

1. Product Identifier
2. Supplier Identification
3. Signal Word(s)
4. Hazard Statement(s)
5. Precautionary Information
6. Pictogram(s)

Not only are these elements mandatory, but the execution of items 3-6 are prescribed, with OSHA providing the exact language and symbols that should be used on the label based upon chemical classification.

Pictograms, item number 6 on the above list, may be particularly confusing to untrained employees. They are black hazard symbols on white backgrounds with red diamond borders. There are nine pictograms in all with symbols corresponding to flammables, oxidizers, compressed gases, acute toxicity, health hazards, corrosives, irritants, and environmental hazards. (The environmental hazard pictogram is not mandatory under HazCom 2012.) Pictograms are just one of the reasons employers should consider training employees on GHS formats well before the December 2013 deadline.

Another reason involves the changes to safety data sheets (SDSs) under HazCom 2012. For instance, notice the M for "material" has been dropped from safety data sheets in the sentence above? In theory, an SDS equals an MSDS. However, through the lens of GHS, there are important differences between the two.

SDSs in the GHS format have 16 sections in a strict order. The format is similar to the ANSI standard, with a few modifications. Training employees on the new SDSs should actually be easier than training normally is for safety data sheets, thanks to the predictable layout.

On the SDS, section 2 is unique because it contains all of the hazard warning information found on the label (i.e., pictogram information, signal words, hazard warnings, and precautionary statements). On the SDS, pictograms can be reproduced in color or in black and white. They also can be substituted with the name of the pictogram that should appear on the label. It is important to note that sections 12-15 on the SDS cover information related to the environment and transportation and are not under OSHA's jurisdiction; however, it is expected that most chemical manufacturers will likely adhere to the 16-part layout.

Another benefit to training employees early is that trained employees can be on the lookout for updated SDSs and labels, serving as an early warning system for the employer. Employers will need to take action on the new SDSs once they come into a facility -- for instance, check the SDSs to see whether there are new hazards employees will need to be trained on, and replace old safety data sheets from the MSDS library with the newer ones.

Second HazCom 2012 Deadline: June 1, 2015 (Manufacturers & Distributors)
By this date, manufacturers and distributors must reclassify their chemicals and produce GHS-formatted safety data sheets and labels for items shipping to downstream users. As mentioned earlier, a big change GHS adoption brings to the HCS is the way hazards are classified. Manufacturers and distributors must reclassify their chemicals based on GHS criteria.

In the past, classification was mostly a "yes" or "no" activity. For example, a chemical was either a carcinogen or it wasn’t. Under GHS, classification of chemicals includes the subdividing of hazards into sub-categories based upon their severity. So, using the carcinogen example again, a chemical that is classified as a carcinogen will further be categorized as a category 1A, category 1B, or category 2 carcinogen. (1A is for "known carcinogens," 1B is for "probable carcinogens," and 2 is for "suspected carcinogens.")

Notice how under GHS the greater the severity, the lower the number? This is opposite the way systems such as NFPA and HMIS handle hazard severity; in those systems, the greater the severity, the higher the number. OSHA has said this should not be a cause for confusion because the GHS category numbers are only used on safety data sheets and not labels. Furthermore, HazCom 2012 explicitly permits the continued use of both NFPA and HMIS systems, so long as they do not obscure or contradict the OSHA-required information.

GHS classification also brings substantive differences to some hazard classes, such as combustible liquids, which are now called flammable liquids. Additionally, OSHA created three new OSHA-defined hazards that must be addressed on labels and SDSs: pyrophoric gas, simple asphyxiants, and combustible dust.

Once a chemical is classified, HazCom 2012 provides specific language on how to communicate the hazards via labels and safety data sheets based upon its categorization. The important end results for downstream users of chemicals is that after manufacturers and distributors fall into compliance, every SDS and shipping label will be standardized, providing greater consistency of information to employees and end users.

Manufacturers and distributors have until June 1, 2015, to comply and are strongly encouraged to begin the process of reclassification and updating SDSs and labels as soon as possible. Many companies are already through the re-authoring phase, but many more are just beginning, which could create bottlenecks in the marketplace. Many manufacturers and distributors are turning to third-party authoring experts for help so they can remain focused on their core businesses.

When it comes to GHS-formatted labels, manufacturers and distributors will need to be able to produce red-colored borders on pictograms, which will likely mean using a color printer or some kind of preprinted label. If opting for a preprinted label, it is important to know that OSHA will not allow any empty pictograms on the label, so care must be taken to ensure there is a one-to-one match between symbol and red diamond.

Third HazCom 2012 Deadline: Dec. 1, 2015 (Distributors)
Distributors get an extra six months to distribute products with old labels and SDSs. The last day for distributors to divest themselves of old products is Dec. 1, 2015. OSHA granted this extension to accommodate distributors that may receive shipments too near the June 2015 deadline to easily comply with it. However, by December 2015, all manufacturers and distributors operating in the United States must be fully compliant with GHS.

Given the second and third deadlines, employers should expect to see nearly their entire SDS library turn over in a relatively short timeframe. It is one key area where electronic management of SDSs can provide benefits that may ease transition pains. For instance, the best systems can easily track and flag GHS-formatted documents, ensuring the user’s SDS library is up to date.

Fourth HazCom 2012 Deadline: June 1, 2016 (Employers)
By this date, employers must be fully compliant with OSHA's adoption of GHS. They must complete any necessary updates to their hazard programs and workplace labeling procedures, and all affected employees must be trained on any new hazard or safety procedure identified during the chemical reclassifications done by manufacturers and distributors.

As with the employee training on how to read GHS formatted SDSs and labels, employers may not wish to wait until the deadline before getting into full compliance. Either way, at no time will employers be exempt from complying with either the old HCS or the new (or some combination of the two). In other words, employees must not lose any of the protections they had under the old HCS.

Many employers have questions about how to best produce HazCom 2012-compliant workplace labels (also called secondary container labels or in-plant labels). This is one area where OSHA is a little more flexible. Employers can continue to use their current workplace labeling systems so long as they take into account new hazard classifications. In other words, workplace labels will continue to be performance based. HazCom 2012 does not specify for employers exactly what has to be on the label. Instead, it tells employers the effect the labels must achieve in regards to providing employees important hazard information. What OSHA says is that the workplace label must provide the same understanding for employees that a shipping label would.

OSHA says employers can either replicate the hazard information found on the shipping label or use "some combination" of the elements (product identifier, signal words, pictograms, hazard statements, precautionary information), which, along with training, achieve the same affect. A way to think about it would be the equation: workplace label + training (must) = shipping label. Best practice is to replicate the information found on the shipping label, which is something a good secondary labeling system can easily do. This, of course, not only provides the best information for employees, it also provides the most compliance coverage for employers.

Finally, employers should have mostly their entire SDS library swapped out with GHS-formatted SDSs. While it is not necessary for employers to seek out new safety data sheets for old products where the manufacturer is out of business or from whom the employer no longer receives shipments, it is incumbent upon the employer to ensure it has updated SDSs for every product it receives from manufacturers after the June 1, 2015 date. The SDS must be in hand before employees are exposed to the product.

Conclusion
There is a lot of work to do over the next couple of years. While June 1, 2016, may seem a long way off, it is likely to come more quickly than employers will want. By starting now, there should be plenty of time for manufacturers, distributors, and employers to transition safely and efficiently to GHS and HazCom 2012 compliance. Furthermore, employers still using paper-based solutions to manage SDSs might want to consider the ways an electronic system can provide additional resources for tracking and flagging GHS documents and producing workplace labels in the OSHA-preferred GHS format.

This article originally appeared in the June 2012 issue of Occupational Health & Safety.