Transition Tips

As countries around the world continue to adopt the Globally Harmonized System of Hazard Communication (GHS), the question at the top of many lists is, "how will I apply the GHS at my facility?" That is why we have compiled this list of quick tips, designed to help you prepare for the up coming transition.

1. Get Informed – learn all you can about the GHS and be on the lookout for information related to the new changes to best determine its potential impact on your organization. Find a good resource for gathering GHS related information and check it often. The website www.ghsinformation.com is an excellent source and also provides a free newsletter, which will send timely news directly to your inbox.
2. Timeframes – be sure you are aware of implementation dates in your country as well as in the countries with which you do business (see the timeline on the www.ghsinformation.com home page for information by country). Also, be aware of the differences in adoption between countries as it may affect your exportation processes.
3. Don't Go It Alone – make sure your product and service providers have a transition plan in place and are able to support you as you make the necessary changes; this includes vendors who assist with: training, (M)SDS management, authoring new compliant documents, labeling, and transportation. Will they be able to assist you as you transition to the GHS? Are they informed about the GHS and will they be a useful resource for you?
4. Vendor (M)SDS Management System – support your transition with a chemical information management system that will aid in the administration of documents classified under existing and future regulations. Be sure your system is ready for the GHS and is able to provide a consistent and clear message to your employees, even in the event the (M)SDS does not. How will you deal with vendors who are slow to transition to the GHS and provide the updated (M)SDS requirements your employees need? Does your (M)SDS management system provide a means for tracking the new GHS classifications and pictograms? If your chemical vendors are slow to respond to the GHS, can your MSDS Management system offer GHS classification guidance to assist with consistent messaging for your employees?
5. Workplace Labels – workplace labels will need to be updated to include the new pictograms and statements. To en-sure workplace safety and allow for consistency, GHS labels may need to be created before an updated vendor (M)SDS is available. How will you create such a label and classify it appropriately? Contact your labeling vendor to find out how they plan to assist you with compliance for the upcoming label changes. If your Vendor MSDS management program is able to track the new fields and classifications, can it also provide a GHS compliant label?
6. Product (M)SDS Authoring and Distribution – how will you reclassify your products according to the GHS and how will that information be distributed to your customers? Be sure your authoring method will support GHS classification according to the various countries' requirements, and that it will be able to create the necessary associated product labels and documents. You might consider adding an addendum with the GHS classifications and related pictograms to your existing product (M)SDSs during the interim period, before full implementation is required. Explore your options with respect to distribution, a validated electronic distribution method could greatly assist in allaying some of the costs associated with such a large project.
7. Training Program – training will be a key component of your overall GHS approach and should incorporate information as it is introduced into the workplace. Employees and emergency responders will need to be trained on all new elements they will be faced with, from hazard statements to pictograms. Bear in mind, if products are imported from countries that implement the GHS prior to the US, your employee training may need to begin earlier than expected. The sooner you begin planning your training approach, the more likely you will achieve a successful transition. It is not too early to begin familiarizing your employees with the upcoming pictograms and (M)SDS format changes.

OSHA estimates that, in the US alone, over seven million workplaces and 945,000 hazardous chemical products will be affected by the GHS. While the implementation of GHS in the US may not occur until late in 2008, the changes will be far-reaching and vast in nature. Because other countries like Japan have already implemented the GHS for many chemicals, your employees could be faced with the new documentation very soon. Bear in mind, thoughtful preparation is the best way to ensure a successful and smooth transition.