Can GHS Work?

Safety Data Sheets will for the most part grow exponentially. And they still will be written by technical professionals for technical professionals.

The Hazard Communication Standard (HCS, 29 CFR 1910.1200) was introduced by the Occupational Safety and Health Administration in the mid 1980s in an effort to ensure American workers would be provided with information and training they needed to work safely with hazardous chemicals. The basic premise of the standard as stated in 29 CFR 1910.1200 is, "employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working." It is further stated that "Knowledge acquired under the HCS will help employers provide safer workplaces for their employees. These efforts will help prevent the occurrence of work-related illnesses and injuries caused by chemicals."

What a great idea -- let's make this a performance-based standard (which OSHA did) and allow employers to have the flexibility to develop their own chemical safety programs to meet their needs. And to make certain that employers have the tools they need to do this effectively, we will mandate that chemical manufacturers and distributors create and provide (to employers) a Material Safety Data Sheet for each product they market. These efforts will somehow prevent chemical-related illness and injuries.

You've got to be kidding! Most employers would agree it's necessary to provide information and training that will ensure the safety of their employees, but do you honestly believe an employer who is trying to keep the doors open and make a profit is going to take the time to sift through an MSDS in its current format in an attempt to extract the information needed to make this happen?

And yet, year after year, employers diligently prepare their lists of hazardous chemicals, gather MSDSs, place them in yellow binders, and attempt to teach employees how to read and interpret the data. The obvious elephant in the room here is that employers remain hopeful that their efforts will somehow magically make their workers safer and protect them from the risk of a fine or lawsuit. Unfortunately the same illusion will prevail if the Globally Harmonized System of Classification and Labeling (GHS), scheduled to take effect in 2011, is introduced in the same fashion, because safety through osmosis will never work.

Most readers are now well aware that OSHA is proposing a rule change to modify the current HCS to align with GHS. GHS provides a single set of harmonized criteria for chemical manufacturers to classify their chemicals according to their health and physical hazards in classes, such as Flammable Gases, Flammable Liquids, Self-Reactive Substances, etc. The classification of products under GHS also will include mixtures.

The primary benefit of the GHS is to increase the quality and consistency of information provided to workers, employers, and chemical users by adopting a standardized approach to hazard classification, labels, and safety data sheets. OSHA will be adopting several core components of the GHS.

Key Changes
The rule change will not affect the performance-based approach of the current HCS, and thus employers still will be required to demonstrate that they have provided information and training in a manner that proves their employees understand the hazards to which they are exposed. To understand how these proposed rule changes can affect you as the employer and your employees, let's look at several of the changes.

Chemical labels in the near future will include the chemical or product name, signal word, hazard statements, and associated pictograms. There is little doubt this will be a vast improvement over the current system. However, if the labels also must include the precautionary statements, this additional information may be so overwhelming that the average user may choose simply to ignore the information entirely.

MSDSs will be renamed Safety Data Sheets (SDSs) and, for the first time since the HCS was introduced, they will be standardized utilizing the 16-section GHS format.

Will the SDS be better than the current MSDS? Yes, in as much as the user always will be able to locate the information in the same section on every SDS. Due to the amount of additional data required on an SDS, however, such as the precautionary statements, SDSs will for the most part grow exponentially. And if you think the data are going to be any less technical than those presented on the current MSDS, think again. SDSs still will be written by technical professionals for technical professionals. So even as important as an SDS may be to employees' health and safety, it is very doubtful you will ever find them reading one during their lunch break.

The GHS classifications that OSHA is proposing are criteria-based; for several hazards, the GHS criteria are semi-quantitative or qualitative, and "expert judgment may be required to interpret these data." There are 17 classes based on physical hazards, 10 based on health hazards, and two based on environmental hazards. These classes are further divided into categories that represent varying severity of hazard.

At present, Material Safety Data Sheets in the United States are not harmonized. Often they contain insufficient, contradictory, or even incorrect information, a situation that will change as OSHA incorporates GHS-based hazard communication.

Important SDS Data
By now, you must be wondering whether there is a rational answer to developing a successful hazard communication program hidden somewhere in all of this confusion. While I think the answer is yes, it may require you (the employer or the EHS manager) to spend some time pulling it all together.

GHS requires manufacturers and distributors to use standardized hazard statements, pictograms, and signal words to denote hazards, and these will be readily available on the new SDS. These three important criteria immediately inform a worker that there may be a danger associated with the chemical to which he or she is about to be exposed. Additionally, the hazard statements indicate the route of exposure through which a chemical may enter the body.

What other practical information can you gather from an SDS? For one thing, an SDS will provide you with a list of the target organs that may be adversely affected by exposure to the hazardous chemical product or substance, even in small quantities, so why not add these to your list of three? I often to explain to audiences that our body's target organs, such as our liver, lungs, or skin, act like the oil filter in our car.

It is common knowledge that an oil filter must be changed periodically (most people are diligent about this task) to protect our automobile's engine so that it doesn't wear out. I am always quick to point out that if we lose our body's target organs or they fail to perform the task for which they were intended, we cannot purchase a new one from the local automotive parts house. Remember that the next time you see a person walking around tethered to an oxygen bottle on a little cart: If you lose your lungs, you lose your choices!

So if we cannot readily purchase a new target organ, what measures can we take to ensure they are protected from the potentially adverse affects of using a hazardous chemical to perform our job? The answer comes from the next piece of information we should extract from a SDS, which of course is personal protective equipment that our employees should use when working with this chemical.

Putting the Information to Use
There is going to be a vast amount of new information associated with the proposed OSHA rule change, but if you know what information to look for and how to present it to your employees, you could in fact finally have a very successful hazard communication program.

This year, as you are making a list of the hazardous chemicals in use at your facility, take the time to identify from the SDS what the associated hazards of each are and include this information in your list. Once you have completed this task, identify the target organs that may be affected by the use of each chemical on the list, the routes of exposure (how the chemical gains access to the body), and finally the PPE needed to keep this from happening. Present this information to your employees in a manner that they understand, and you have the basis of a functional workplace safety program.

This article originally appeared in the September 2011 issue of Occupational Health & Safety.

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