Essential Next Steps on GHS

The GHS format is no panacea for comprehensive hazard communication, and several significant problems remain to be solved.

• By Tom Jacques
• Jan 01, 2013

It is often said that "you can lead a horse to water, but you can't make him drink." This is especially true when we are not getting the desired results from just about any project involving human beings. I have heard this statement uttered hundreds of times from safety professionals when they inform me that they provide safety data sheets (SDSs) to their employees, but they never look at them anyway. Thus, "you can lead a horse to water, but you can’t make him drink" -- what a cop-out. Try giving him salt.

At the end of the day, when an employee is injured or becomes ill due to a chemical exposure, the presiding judge or, worse yet, a jury will not and should not consider this statement as a defense, or even an acceptable response to the charges. And neither should you.

I recently attended the safety conference of a very large, well-known manufacturer, where the corporate EHS director said to his staff, "If our employees are injured or become ill due to a chemical exposure on the job, it is a failure on our part as safety professionals to have performed our duties correctly." This bold statement is one all of us should take very seriously.

We have long since passed the time when ignorance can be used as an acceptable defense. In our litigious society, a safety officer, CEO, or other corporate officer may be held accountable for his or her actions or lack thereof when it pertains to an employees' safety. If our employees are not accessing the SDS information provided to them, for whatever reason, it is in our best interest to identify a better method to make certain they are working safer with chemicals and we have truly met our obligations.

GHS
OSHA has adopted several key components of the Globally Harmonized System of Classification and Labeling of Chemicals, (GHS) as part of the Hazard Communication Standard. We referred to the 1983 OSHA rule as the employee right-to-know; the new standard, HazCom 2012, often will be called the employee right-to-understand. While this may appear to be just a play on words, soon you will realize this statement and the intent of the new OSHA rule changes may have far greater implications than you may think.

1. OSHA claims that "implementing GHS will enhance worker comprehension, resulting in appropriate handling and use of chemicals." The big question is, how will this monumental event happen, through osmosis or some parting of the heavens? I am not trying to make light of OSHA's statement, but unless we have a wholesale change in how we approach chemical safety, the reality is this goal will not be achieved in most workplaces because most employers and employees never look at an SDS.

This claim by OSHA assumes your hazard communication program is proactive, which simply is not the case if we are totally honest with ourselves. Employers and employees are conditioned to access an SDS (through a variety of vendor services) only when there is an emergency. This is a reactive approach that is contrary to the OSHA mandate that states: "Each employee who may be 'exposed' to hazardous chemicals when working must be provided information and trained prior to initial assignment to work with a hazardous chemical, and whenever the hazard changes." Furthermore, the reactive approach fails to prevent long-term, work-related exposures that may cause chronic illness.

If your employees did actively attempt to review an SDS prior to using a chemical, they would encounter information that is so technical and confusing that they would just give up. The fact is, SDSs were intended for multiple audiences, and hence they are written by technical professionals, such as people with Ph.D. or master's degrees in chemistry or toxicology, and then are finalized by an attorney. Few employees who really need access to this technical information have more than a high school education, and many have comprehension skills that are at or below an eighth grade level. So, once again, how will introducing GHS into the mix enhance worker comprehension?

According to OSHA, "For any safety and health program, success depends on commitment at every level of the organization. This is particularly true for hazard communication, where success requires a change in behavior." Insanity has often been defined as doing the same thing over and over again expecting different results. If we continue to maintain SDSs just to meet our compliance requirements and do not find a way to disseminate the information in a manner that our employees truly understand, we are destined to have the same lackluster results with our safety program for the next 30 years.

Understanding What's Hazardous
A famous actor once said, "It's not that they don't get it, rather it is that they don't buy it!" Sadly, we are programmed to believe that if we are not bleeding and have no broken bones, then everything is just fine. We assume we are not in any danger. Yet according to the American Lung Association, occupational lung disease is the leading work-related illness in the United States based on the frequency, severity, and preventability of diseases. These diseases are usually caused by extended exposure to irritating or toxic substances that may cause acute or chronic respiratory ailments, although severe single exposures can cause chronic lung disease, as well.

While occupational lung diseases often are not curable, they are always preventable. Improving ventilation, wearing protective equipment, changing work procedures, and educating workers are the key factors for prevention. We need to modify our behavior if we expect our safety programs to be successful, and I would suggest we begin by rethinking how we view what is hazardous and what is not. For example, when we review the SDS for a common spray adhesive, we find the manufacturer has correctly classified this product under GHS as an extremely flammable aerosol. This would generally indicate we need to keep this product away from open flames. Upon further review, however, we also discover this product is an irritant and can affect both the central and peripheral nervous system and the upper respiratory system.

You are probably thinking your employees do not inhale enough of this product to matter with just a single use, but what if they were to use three or four other aerosol products with the same characteristics today? Remember, respiratory diseases usually are caused by extended exposure to irritating or toxic substances that may cause acute or chronic respiratory ailments. Many workplaces contain hundreds if not thousands of hazardous chemicals in various forms. Some chemicals are necessary, and some we use just because they are convenient and save a little elbow grease. Either way, we need to look at all of the hazards, not just a few. Maybe we should consider changing a few work habits or purchasing habits while we're at it.

Following the new OSHA guidelines, chemical manufacturers are required to reclassify their chemicals in accordance with the criteria established by GHS, which was the case with the spray adhesive mentioned in the previous paragraph. In this example, the manufacturer identified several additional hazards, providing us with information we might not have had before GHS.

Lingering Concerns
The promulgation of the Hazard Communication Standard in the early 1980s was a political compromise between the U.S. Department of Labor and industry, resulting in many loopholes that enabled the parties to arrive at a consensus. The net effect was a lack of standardization of safety data sheets, which had hundreds of different formats and, of course, are filled with contradictory and inadequate information. As the United States has become a signatory to the GHS, SDSs will have to become standardized. The introduction of pictograms and hazard and precautionary statements will help in reducing confusion, but the GHS format is no panacea for comprehensive hazard communication, either.

Some problems that remain include these:

1. There continues to be no requirement for testing of the product. A manufacturer still can extrapolate data from other chemicals or base critical information on a single ingredient.

2. GHS was developed for industry, so it does not directly cover requirements for workplaces such as health care facilities, which have hazardous drugs, biohazardous materials, and radioactive isotopes.

3. There is still too much focus on individual chemicals, not on what happens to them when they are used with or interact with other chemicals during the manufacturing process. Often very toxic and or corrosive byproducts, such as fumes and nuisance dust, are generated during the processing of the product. Fumes and dust particles have long-term health effects, yet for the most part the problem is not addressed. For example, an alloy is perfectly safe and toxic fumes are generated during the welding process, and so focusing on the hazards of the alloy can be misleading.

4. For whatever reason, GHS has not addressed water reactivity of chemicals. There is no class for such products.

An effective Hazard Communication Program must attempt to interpret all of the technical information from the SDSs, provide training that is thoroughly understood, and go beyond the mandated requirements by warning employees of additional hazards during the processing so they can protect themselves from noxious fumes and dust.

This article originally appeared in the January 2013 issue of Occupational Health & Safety.