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Six Tips for Health Care Facilities and Labs to Ensure GHS Compliance

Flexible, lower-cost options enable printing durable, appropriately-sized GHS, HMIS, NFPA, or hybrid labels on demand for smaller “down-packed” chemical container labels.

Health care facility and laboratory end users—from hospital, medical office, medical lab, and research lab managers to environmental health and safety (EHS) compliance officers—must be confident their chemical labels are GHS compliant. 

In the United States, OSHA set a June 1, 2016, deadline for end users to update their workplace labels. If compliance is lacking, health care and lab end users must be prepared to document for OSHA their good-faith efforts to become compliant, including an expected timeline for achieving it.

The Globally Harmonized System (GHS) was established by the United Nations to create a unified system for identifying and communicating hazardous chemicals. According to OSHA, the new standard covers more than 43 million workers who produce or handle hazardous chemicals in more than 5 million workplaces across the country.

GHS compliance is required even for chemical formulations purchased in bulk containers for cost savings, such as barrels of disinfectant, sanitizer, or sterilant, that are transferred to smaller "down-packed" containers, such as bottles, for portable use. Container sizes requiring GHS-compliant labeling generally range from 55-gallon drums down to spray bottles and even small samples or test vials.

In health care facilities, powerful chemical sterilants such as ethylene oxide are used to sterilize moisture and heat-sensitive instruments. High-level disinfectants such as glutaraldehyde are often used to disinfect heat-sensitive equipment such as endoscopes, bronchoscopes, and surgical, dialysis, as well as ear, nose, and throat instruments.

Medical and diagnostic tests are also performed daily in medical or research labs, where chemical hazards from toxins, flammables, and reactives to corrosives and radioactives are present. Labs, in fact, use large amounts of some chemicals, such as xylene, formalin, and alcohol, as well as smaller amounts of many others. Automated chemical analyzer systems, for instance, contain reservoirs of reagent, as well as reagents with preservatives.

With the just-passed GHS deadline for health care facility and lab end users in mind, here are six tips to quickly get up to speed on GHS regulation and ensure compliance for even smaller “down-packed” chemical container labeling.

1. Have GHS-compliant safety data sheets and labels and train workers to handle hazardous chemicals properly. On each GHS label, six items of data are required:  Product Name or Identifier; Hazard Statement; Signal Word; GHS Pictogram symbols; Precautionary Statement; and Supplier Information. 

Instead of the familiar black-and-white pictogram symbols previously used in safety labeling, GHS labels now require pictogram symbols that convey hazard information with a red diamond border.

2. Label all secondary containers. If a chemical is supplied to the workplace with a GHS label, it must be maintained. If the chemical is transferred to a secondary container, such as a tank or bottle that stays in the workplace, employers may label it with information from the original GHS shipping label or safety data sheet.

However, employers may choose to use an alternate system, such as the National Fire Protection Association's (NFPA) Standard 704 or the American Coatings Association (ACA)'s Hazardous Materials Identification System (HMIS®). If using an alternate system, the employer must ensure the information is consistent with GHS and that workers understand specific physical and health hazards.

If a chemical is transferred to a "portable" secondary container, such as a flask, beaker, or dropper bottle, for use only by the person who transferred it during the same work shift, a label is not required because it is considered "immediate use."

3. Save on printing with durable label options on demand. For those currently using HMIS or NFPA labels for health care or lab containers, related written documentation, and training, the question is how to achieve GHS compliance and integrate it with HMIS or NFPA, which have been used for decades. 

Though differences exist in GHS, HMIS, and NFPA, such as opposite numbering for GHS level of hazard, OSHA allows employers to use HMIS and NFPA in the workplace as long as they are consistent with GHS (HCS 2012) and workers are properly trained for GHS.

Implementing GHS labeling can seem daunting to industrial end users, but it does not have to be. Many are turning to flexible, lower-cost options, such as industrial-grade labels that allow printing durable GHS, HMIS, or hybrid labels on demand with existing laser printers and pigment-based inkjet printers. Unlike standard labels, industrial labels are used in harsh environments and so must be very durable and able to withstand exposure to chemicals, abrasion, tearing, moisture, sunlight, and high temperatures.

4. Meet rugged GHS industrial requirements to stay compliant. The challenge is that, to be GHS compliant, labels must stay reliably affixed without fading or becoming unreadable, despite harsh conditions that include exposure to chemicals, moisture, and spills.

Some industrial label companies have designed their labels to meet rigorous GHS requirements. One type is chemical resistant, tear resistant, abrasion resistant, and constructed with a marine-grade adhesive that is waterproof and passes a 90-day seawater submersion adhesion test. Unlike typical labels, which crack and harden in harsh conditions, the GHS labels are also very UV and temperature resistant.  In addition, they resist harsh chemicals such as acetone and MEK when printed from pigment-based inkjet printers.

"Staying GHS compliant will not only help health care and lab end users avoid OSHA fines, sanctions, or auditing, but also position them ahead of the curve if other industry standards are allowed to sunset," said Glenn Hallett, president of RightAnswer.com, Inc., a chemical compliance and information specialist.

Hallett notes that remaining GHS label compliant depends on the durability of the appropriate label substrate, getting the label content right, and effective document management.

"Health care and lab settings that have long used HMIS labels will now also want the ability to print GHS labels, HMIS labels, NFPA labels, or some alternative that will accommodate their requirements," he said. "Such flexibility will help ease the industry’s transition to GHS labeling and minimize any operational disruption."

5. Take advantage of free label-printing software. GHS-, HMIS-, and NFPA-compliant label software is available at no cost. Employees can create and print their own GHS and HMIS labels from pre-designed templates, create on-demand labels step by step at their desk, and create GHS and HMIS hybrid labels capable of satisfying both systems. Most employees find such a process intuitive, since it resembles creating an office document from pre-designed templates.

The software includes the pictograms and GHS compliant statements needed for GHS labeling; allows customizable text and the insertion of logos or other images; generation of 18 types of barcodes; and a sequential numbering feature to add lot numbers or other variable data. 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 DOT labels.

6. Choose GHS labels that work with the full range of container sizes and container surface types. GHS and HMIS labels are available in a range of sizes—to fit drums, totes, pails, cans, jugs, containers, and even small bottles—that can be applied to a variety of surfaces, such as metal, plastic, glass, ceramic, polycarbonate, painted surfaces, and more.

This article originally appeared in the July 2016 issue of Occupational Health & Safety.

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