Revisiting GHS Label Compliance One Year After OSHA's Deadline

A new survey shows more than 21 percent of companies did not meet all GHS compliance requirements.

• By Colwin Chan
• Jul 01, 2017

One year after OSHA's June 1, 2016, "Globally Harmonized System" (GHS) label end user deadline, more than 21 percent of companies had not yet met all requirements, according to a new survey. The survey, conducted by Occupational Health & Safety magazine and Avery Products Corporation, an industrial and consumer label provider, reveals the perceived top barriers to GHS label compliance.

Fortunately, the tools and strategies exist that can help small to mid-sized companies achieve GHS label compliance rather quickly and inexpensively. With higher OSHA penalties making non-compliance more costly, taking advantage of these tools and attaining compliance is more important than ever.

"The OSHA GHS label deadline for end users has come and gone, and it is now a costly compliance issue," said Christine Webb, CSP, a consultant at Avitus Group, a U.S.-based provider of services that allow small companies to strengthen and grow their businesses. Some of these services include safety, compliance, training, payroll, and more.

Webb, who is a former OSHA compliance officer, noted that, last year, Congress enacted a bill that allowed federal agencies to raise their fines, which had not been updated in decades.

"OSHA increased its fines by 78 percent, so a more severe citation that could cost up to $7,000 previously can now cost over $12,000," she said. "Not having appropriate GHS labels on secondary containers is one of the easiest compliance issues to spot and cite."

In an industrial setting, chemical formulations that could require GHS labeling range from industrial primers, coatings, and sealants to lubricants, greases, cutting oils, and rust removers, to acid, alkaline, and solvent-based cleaners, to degreasers, surfactants, disinfectants, and sanitizers.

Overcoming Barriers to Compliance

1) GHS Label Content
According to the survey, more than 26 percent of respondents stated that finding and placing compliant GHS content onto the label has been the most challenging part of the labeling process for them. Too often, this has involved tracking down difficult to obtain updated safety data sheets, determining the key data, and printing it on the GHS label in the correct format, which does require GHS pictograms.

On each GHS label, six specific items of data are required: Product Name or Identifier; Hazard Statement; Signal Word; GHS Pictogram symbols; Precautionary Statement; and Supplier Information. In place of the familiar black and white pictogram symbols previously used in safety labeling, GHS labels require pictogram symbols that convey hazard information with a red diamond border.

"A lot of people still don't fully understand GHS labeling requirements, particularly at the small to mid-sized company level," said Webb. "They are unsure of what goes onto a GHS label and how to get it."

Webb noted that, as a safety and compliance consultant, she often shows clients how to use free GHS label software available online and how to print labels from their desktop printers. Such GHS label software is intuitive, like using an app or a Microsoft Word template, she said.

The crucial GHS label data can be accessed almost instantly from online databases and formatted to GHS requirements. Much of the necessary information can be obtained, in fact, by simply entering a substance's Chemical Abstracts Service (CAS) number.

"GHS label chemical info can be found on some label company websites," Webb said. "My clients save it on their PCs so they don't have to go back online. They print GHS labels from desktop printers and put the labels on containers as needed."

The software includes the pictograms and GHS compliant statements needed for GHS labeling, allows customizable text, and insertion of company logo or other images. For more sophisticated uses, it can generate 18 types of barcodes and has a sequential numbering feature to add lot numbers or other variable data.

No download is required because the cloud-based GHS software operates from the label company website, and GHS, HMIS, and NFPA labels can be securely saved online or to a computer. The software is also capable of printing other safety labels, such as OSHA, ANSI, and arc flash labels.

2) GHS Label Durability
More than 24 percent of survey respondents indicated that another challenge was finding durable labels that can withstand chemicals and harsh environments. According to Webb, who consults with clients from a wide range of industries, some people mistakenly try to use regular office-grade labels for GHS applications but find that the labels peel or the ink fades in tough workplace settings.

"GHS labels must be durable to stay compliant," she said. "In machine shops and auto body shops, for instance, the labels must resist oil, grease, and solvents, and in restaurants and kitchens hold up to harsh cleansers and disinfectants. In such applications, GHS labels can withstand solvents, degreasers, cleansers, as well as abrasion and moisture."

Durable synthetic labels are chemical resistant, tear resistant, abrasion resistant, and constructed with a high-performance adhesive that is waterproof and passes a 90-day seawater submersion adhesion test.

Unlike typical labels, which crack and harden in harsh conditions, they are UV resistant with 2+ years of outdoor UV life. They are also temperature resistant and can be applied as low as 10° F, with adhesive service temperatures that can range between -40° F to as high as 300° F.

For extra protection in harsh environments, Webb likes to use an additional laminate over the top of GHS labels. Some label companies offer such labels with a clear laminate so no lamination machine or additional layer of tape is needed. The material is UV and water resistant and resists scuffing, tearing, and smudging, making them ideal for use in warehouses, storage areas, and work sites.

3) GHS Label Size
According to the survey, almost 11 percent of respondents stated that "finding labels that fit my containers" was a problem. For end users, GHS compliance is required for chemical formulations purchased in bulk containers for cost savings, such as barrels of industrial cleaner that are transferred to smaller "down-packed" containers, such as spray bottles, for portable use.

Containers requiring GHS-compliant labeling can vary in size from 55-gallon drums down to little test vials.

"Getting correctly sized GHS labels can be a challenge," Webb said. "With GHS labels, you usually don't want labels of only one size or type, not when you could have a dozen or more different types of containers. For my clients, I look to well-known label companies that offer the widest range of GHS label sizes and types."

Such GHS labels are available in a full range of sizes to fit drums, totes, pails, cans, jugs, containers, and even small bottles. They can be applied to a variety of surfaces, such as metal, plastic, glass, ceramic, polycarbonate, painted surfaces, and more.

"Even if you are an end user at a small or mid-sized company, compliance is easier than you think with easy to use GHS label software and labels that you print at your desk," she said. "You can get in compliance quickly, avoid higher OSHA penalties, and keep your employees and workplace safe and productive."

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