Wholesale adoption of GHS hazard classsification principles will disrupt chemical hazard assessment programs and heighten problems manufacturers and importers will face.

Understanding Chemical Safety Following the Final GHS Deadline

Don't view the conclusion of this round of GHS deadlines as the end of the process, but rather the beginning of the new state of HazCom and what OSHA now expects for compliance.

Following a decade-long effort, the final effective completion date to align OSHA's Hazard Communication Standard (HazCom) with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS) has come and gone. While companies covered by HazCom may see the conclusion of the GHS deadlines as an ending, it's critical that they view the changes enacted with GHS alignment as just the beginning. Moving forward, OSHA will not only continue to enforce the current GHS modifications to its HazCom Standard, but the agency has also expressed intent to review and possibly update the rule in the future to align with newer versions of the GHS.

Is your facility fully GHS aligned and prepared for any future GHS-related modifications to the HazCom Standard? Following are the key steps you should perform now, not only to safeguard employees from hazardous chemical dangers, but also to ensure your facility remains in compliance.

Step One: Organize Your Chemical Inventory
Having an accurate chemical inventory creates the foundation for effective chemical management initiatives and is a key building block to ensuring compliance with GHS updates to HazCom. Without a true understanding of what chemicals you have and where they are, it's impossible to know what products should be on your radar and accounted for in your hazardous chemical management, reporting, and compliance strategy. As part of your overall strategy, ensuring an updated inventory will allow you to more easily identify chemicals that are missing their corresponding safety data sheets (SDSs) or have out-of-date versions that should be replaced.

A good first step is to follow the chemical inventory list located in your written HazCom program (in the event that you don’t have a chemical inventory list in your written plan, now is the time to do this because it's a mandatory component of a compliant OSHA HazCom program). Take your time walking through the facility, noting any inconsistencies with chemicals, locations, or amounts. Make sure the chemical manufacturers’ names, addresses, and telephone numbers line up with what is recorded on the inventory list and SDS; this will be key if you need to contact them for any updated documentation.

Once you've completed the physical inventory of the chemicals in your facility, the next step is to ensure that you have a current SDS for each chemical on your list. During the official GHS transition period, many downstream chemical users experienced a delay in receiving updated SDSs to replace their older formatted MSDSs from manufacturers. While OSHA recognized this issue, the agency made it clear that it was your responsibility as the employer to take measures to ensure your facility had the most updated SDSs available to workers for products coming in following the deadline period without updated SDSs.

Chemical manufacturers and distributors are required to send a GHS-aligned SDS of a chemical with the first or the next shipment after an update to the SDS document occurs. If you've received a first or next chemical shipment on or after June 1, 2015, and it didn't include the new SDS, you should have requested it from the supplier. If the supplier didn’t have one ready, you should be prepared to relay that information to OSHA. In other words, you need to be able to demonstrate to OSHA that this was not something you accepted passively and made all attempts to rectify.

Any attempts you made to obtain the documents should be recorded, including the date of the original shipment and exactly what manufacture documentation was missing (i.e., updated shipped label, updated SDS, or both), along with records of any calls, emails, and letters to the supplier showing your attempts to resolve the matter.

Fortunately, today, a good EHS software solution can simplify many of these complex chemical inventory management tasks and provide more efficient control needed to account for every chemical, at every location, even down to specific containers. Users can store SDSs in online databases specific to their company, providing quicker access to the critical safety information when needed. Inventory checks become easier with corresponding SDSs at your fingertips instead of having to manually locate the documents in three-ring paper binders.

Many of these solutions offer online access to safety data sheets or services to help locate SDSs from manufacturers, and they even offer mobile accessibility, making access to chemical inventory information from the field easier. Some of the more sophisticated solutions allow you to track chemicals using smartphone and tablet cameras to scan container barcodes, QR codes, and UPC codes and to use the scanned information to pull up reference data about products in your inventory. In addition to the mobile-optimized functionality offered by today’s leading EHS software providers, a handful also feature mobile applications that provide offline accessibility when Internet connectivity is limited or unavailable.

Step Two: Establish Ongoing Training Procedures
One important issue the first GHS training deadline uncovered was that some employees may never have received adequate HazCom training in the first place or had been trained so long ago that they hadn't retained a basic understanding of the standard in order to be able to put the GHS modifications into context. As a result, the first GHS training deadline not only served to provide workers with information about the new GHS-aligned SDS and shipped-label formats, but also supplied a much needed refresher course on HazCom in general.

While OSHA does not require employee training to be performed at a specified interval, regular training—even annual training—is a best practice that will help ensure your employees retain critical HazCom information. OSHA, however, does stipulate that training must occur when a new employee is hired. They must be trained to understand the hazards associated with both the chemicals they will be interacting with and those they may potentially be exposed to in the course of their work day.

Similarly, if a new chemical is introduced into your facility, employees who might come into contact with that substance must be trained on its potential hazards, as well. Again, a comprehensive EHS software solution can streamline the administrative tasks of implementing and tracking employee training. Many include features that not only help you track your training needs and streamline communication to employees about completion deadlines, but some also provide access to a wide variety of on-demand safety courses to help you meet your compliance requirements.

Regular safety trainings also will become useful as OSHA continues to modify its HazCom Standard with updated versions of GHS. Not only will employees already have a strong knowledge foundation of the current rule to understand any changes, but they will most likely be more receptive to the new information with existing—and expected—training  procedures already in place.

Step Three: Update Your Labels
Consistency in the labeling of hazardous chemicals is a fundamental element of GHS adoption. The GHS-aligned HazCom standard outlines six specific elements required to appear on manufacturer shipped container labels. They are: product identifier, signal word, hazard statement(s), precautionary statement(s), pictogram(s), and supplier information. However, when it comes to workplace labels, compliance is performance-based. This means compliance will be determined by how well the labels perform during an OSHA inspection.

To assist employers, OSHA essentially outlined three main approaches employers can take when it comes to workplace labeling (also called secondary container labeling). One, employers may continue to use their current compliant workplace labeling systems—so long as the information accounts for and doesn’t conflict with the new GHS information. Two, employers may use a homegrown system that uses a combination of the manufacturer shipped label elements and other information—so long as workers have been trained to comprehend it and it doesn’t contain any conflicting information. Or, three, simply replicate the manufacturer shipped label.

Replicating the shipped label is considered by many a best practice because it provides greater consistency between the two types of labels employees encounter in the workplace. Employees already should be trained on the GHS-aligned manufacturer shipped label format, so this approach also eliminates the need for additional training on a separate label system and lessens the burden placed an alternative label to perform as effectively as the shipped label. Here again, the leading electronic chemical management systems will include features that can help you easily produce GHS-aligned workplace labels using information taken directly from a product’s SDS.

Whatever approach you take, you should make sure your current workplace labeling system can perform during an OSHA inspection to indicate that employees have all of the information needed about hazardous chemicals in the workplace, including those newly identified as a result of GHS adoption.

Step Four: Be Prepared for What May Come Next
While the final GHS deadlines have come and gone, it's prudent to remain prepared for any additional changes to come. A good industry best practice is to designate a GHS transition leader. Such a person would have a familiarity with both current and potentially new GHS requirements and your site-specific GHS transition process and would be able to employ his or her knowledge and experience to drive the implementation of any future GHS changes resulting from OSHA’s adoption of newer editions of the global system.

Most importantly, do not view the conclusion of this round of GHS deadlines as the end of the process, but rather the beginning of the new state of HazCom and what OSHA now expects for compliance. With the phased-in period behind us, we're now closer to what may be the smaller but still significant GHS-related changes to come.

This article originally appeared in the May 2017 issue of Occupational Health & Safety.

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