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5 Tips for Managing the Messy Transition to GHS

Safety professionals are finding that the more time they spend with the revised standard looking at training, the more questions they have about GHS adoption in general.

OSHA revised the Hazard Communication Standard last year and by Dec. 1, 2013, employers must train workers exposed to hazardous chemicals on big changes the update brings to labels and safety data sheets. OSHA's goal in revising the HazCom Standard was to align it with GHS, the model hazard communication system developed by the United Nations.

Many safety professionals are digging into OSHA's new standard -- called "HazCom 2012" -- to try to understand their training obligations. What those professionals are finding is that the more time they spend with the revised standard looking at training, the more questions they have about GHS adoption in general. Some of the more common questions include:

  • Do manufacturers have to send me new safety data sheets, or am I required to get them myself?
  • What if my chemical supplier does not know about HazCom 2012 or GHS and the changes to safety data sheets?
  • What exactly do I have to put on my workplace labels?

OSHA has provided compliance information on its website, in the Federal Register, and in a series of recently published briefs. Yet, for the uninitiated, finding answers to important questions can be overwhelming.

MSDSonline has been tracking and reporting on GHS for nearly five years. We've taken all of the available information and synthesized it into easy action items safety professionals can use in their day-to-day HazCom program. Following are five tips for you to keep in mind as your organization makes the transition to HazCom 2012. Keep in mind, these tips are not a substitute for the very real requirements outlined in OSHA's new standard, which every covered employer must work to understand and comply with.

Tip 1: Comply with HazCom Basics
According to Jennifer Silk and Maureen Ruskin, two HazCom experts who were instrumental in leading OSHA's adoption of GHS, one of the biggest HazCom 2012 transition issues is that employers were not compliant with the old HazCom Standard, which OSHA is now calling "HazCom 1994." The five key responsibilities employers had under HazCom 1994 are the same key responsibilities you will have under HazCom 2012:

I. Have a written site-specific hazard communication program
II. Keep a list of hazardous chemicals present in the workplace
III. Maintain safety data sheets for all hazardous chemicals and provide Right-To-Know access to employees
IV. Ensure proper use of labels and warning signs in the workplace
V. Train employees on HazCom and specific workplace chemical hazards

If your workplace is not in compliance with items I-V, this is the place to start your HazCom 2012 compliance activities. Having an up-to-date chemical inventory and ensuring there is a safety data sheet for every chemical in the workplace is an especially critical component of managing the transition to HazCom 2012, as discussed below.

Tip 2: Tackle Changes to Labels and Safety Data Sheets
HazCom 2012 standardizes safety data sheets and labels on shipped containers. By June 1, 2015, chemical manufacturers and distributors must reclassify their chemicals using GHS criteria spelled out in HazCom 2012 and then revise their safety data sheets and labels in the formats covered below.

Training your employees on these changes is what the Dec. 1, 2013 deadline is all about. OSHA wants employees trained on the format changes to labels and safety data sheets sooner rather than later because manufacturers and distributors can make the changes any time before their June 1, 2015 deadline. In fact, updated labels and safety data sheets already have entered the marketplace.

Changes to Labels
Labels under HazCom 1994 were performance-based, meaning chemical manufacturers and distributors had discretion as to what to put on the label. OSHA would then determine whether the label was compliant based on how well it performed in the workplace.

Under HazCom 2012, label information is prescribed by OSHA and has six standardized elements:

1. Product Identifier -- Same product identifier as found on safety data sheet
2. Supplier Information -- Including name, address, and phone number of responsible party
3. Pictogram(s) -- Black hazard symbol on white background with red diamond border
4. Signal Word -- Must use either "Danger" or "Warning," depending upon hazards
5. Hazard Statement(s) -- Declarative statement regarding nature or degree of hazard
6. Precautionary Statement(s) -- Descriptions of appropriate prevention, storage, response, and spill measures

For training purposes, employees should know these six elements, how they work together, how the information provides guidance on product handling and emergency response. According to a recent OSHA brief, employers are not expected to update labels on shipped containers, even if labeled with HazCom 1994-styled labels. They are, however, expected to update workplace labels as necessary, as discussed later in Tip 4.

Changes to MSDSs
Safety data sheets get a refresh under HazCom 2012 that includes organizing information into 16 mandatory sections with a strict ordering. To meet training requirements, employer should train employees on the 16 sections and their order, pointing out how Sections 1 and 2 correspond to the information found on the new shipped label and how the document is structured so that emergency response information is up front and the more technical information is in the back.

Another change under HazCom 2012 is that safety data sheets are called SDSs, dropping the M from MSDS. Nonetheless, their role in OSHA's new standard is largely unchanged. If anything, the new 16 section format makes safety data sheets even more central to HazCom compliance because information found on the documents -- especially if they are managed electronically -- can be used as a resource for hazard communication planning, inventorying, labeling, and training.

Tip 3: Be Prepared to Get Messy
HazCom 2012 went into effect on May 25, 2012. Between now and June 1, 2015, employers should expect that almost their entire safety data sheet library will be updated. This is causing some safety professionals to ask whether they have to keep two sets of MSDS books until all of the updates are made. The answer is no. During the transition, OSHA says employers can be in compliance with the old standard or the new standard or a combination of the two.

For example, employers will likely find their MSDS library contains safety data sheets in both the new format as well as the myriad of formats that were allowed under HazCom 1994. Still, even though two sets of books are not required, employers will need to pay special attention to MSDSs as they enter the workplace to see exactly what updates, if any, have been made.

They should especially be on the lookout for chemicals that have newly identified hazards listed on the safety data sheet.

Other MSDS questions many employers have are over the timing of the updates and who has to do what. Some employers worry they must ask the chemical manufacturers for the updated documents or even update the manufacturer safety data sheets themselves. This is not the case (unless they happen to be the originator of the chemical).

Chemical manufacturers and distributors are responsible for sending the updated documents to the end users of their chemicals with the first shipment or the next shipment after a change has been made. This means employers can realistically update their libraries only as quickly as manufacturers and distributors update their own safety data sheets. Manufacturers are not required to proactively send updated safety data sheets to past customers independent of a new shipment.

Now, if an employer receives a chemical shipment after the June 1, 2015 deadline, OSHA does expect the employer to make a good-faith effort to secure an updated document from the supplier.

Exacerbating the safety data sheet issue is the fact that many manufactures seem to be making the move to GHS safety data sheets in stages. For instance, it is not uncommon now to find 16-section safety data sheets with GHS require elements in the wrong places or non-16-section safety data sheets that also contain GHS pictograms and other HazCom 2012 information.

Given this mess, how will employers know if the safety data sheets they receive are HazCom 2012 compliant? The best way is talk with their suppliers and make sure they are up to speed on OSHA's changes (too many chemical manufacturers and distributors are not) and to train their employees well on HazCom 2012.

A good electronic MSDS management system also can help to identify safety data sheets that include GHS elements. If you are still managing MSDS using paper-base filing systems, this may be a good time to start evaluating an electronic solution.

Tip 4: Don’t Forget about Workplace Labels
Questions about workplace labels tend to outpace other HazCom 2012 questions by a large margin. Common questions are, "Can we still use NFPA and HMIS labels? Do we have to use pictograms, and if so, must they have red borders as on the shipped label?"

Under HazCom 2012, workplace labels are still performance based -- meaning OSHA doesn’t tell employers exactly what has to go on secondary container labels, it judges workplace label compliance by how well it does its job: effectively communicating hazards.

OSHA says explicitly in the final rule on HazCom 2012, and elsewhere, that employers can continue to use their current workplace labeling systems so long as they effectively communicate to employees the hazards of the chemicals to which the workers are exposed.

A recent OSHA brief, "Hazard Communication Standard: Labels and Pictograms," says employers can "Either provide all of the required information that is on the label from the chemical manufacturer or, the product identifier and words, pictures, symbols or a combination thereof, which in combination with other information immediately available to employees, provide specific information regarding the hazards of the chemicals."

The standard goes on to say that if employers have their own in-plant system or uses HMIS or NFPA systems, it can continue to do so, so long as the system, in conjunction with other information available to employees, provides workers with all of the health and physical hazards of the chemical. If employers choose to employ GHS elements like pictograms on the workplace label, the pictogram borders may have a black border rather than red as required on the shipped label.

Keep in mind, under HazCom 2012, employees going forward will need to be trained on the GHS formatted shipping label. Any deviation from that style on the workplace label will also need to be addressed via training. For instance, employers using the NFPA system for workplace labels will need to ensure employees are trained on both HazCom 2012 labels and the NFPA system.

Tip 5: Don't be a Hero
Okay, be a hero if you want to, but there is no reason for safety professionals to go through the transition to HazCom 2012 alone. There is a wealth of information online, including free GHS webinars, a GHS checklist, and many GHS related conversations and FAQs.

Additionally, the acceleration of mobile, cloud-based environmental health and safety solutions has made MSDS and chemical management, and online training solutions affordable to even small and mid-size employers. The best-of-breed solutions can help with the influx of safety data sheets, create GHS formatted workplace labels with the click of a button, and give safety professionals a fast track on regulatory reporting.

HazCom 2012 is here. By following the simple tips listed above -- and getting the necessary help -- safety professionals should be able to keep their employees safe and employers on the right side of compliance throughout the GHS transition.

OH&S Digital Edition

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