Happy 2015! The arrival of the New Year means that we are just six months away from the deadline in which all safety data sheets (SDSs) and labels must comply with the new HazCom 2012 standards. This deadline requires companies that manufacture hazardous chemicals to provide GHS compliant SDSs and labels to downstream users. Manufacturers may not ship products lacking GHS labeling from this point forward, and distributors are under the same obligation but have been granted an extra six months to allow for the depletion of existing inventory. Additionally, employers must comply with HazCom 2012 compliance standards for workplace labeling, hazard communications programs and additional employee training for newly identified physical or health hazards by June 2016.
To achieve compliance requires the same focus and determination as one might need to succeed at any other New Year’s resolution. You’re not going to lose those 10 pounds by carving out the exception, like a daily caramel macchiato per se, but by maintaining a healthy lifestyle with better diet and exercise routines. Similarly, one who successfully transitions to GHS, will take a holistic approach to meeting their compliance goals. If you’re ready for the challenge, here are some ideas for New Year’s resolutions to prepare for GHS adoption.
Resolution #1 – Learn about the basics of classification
As the deadline approaches, OHS professionals can expect to receive an avalanche of new SDSs. It is important to know the basics of classification regarding a safety data sheet in order to determine if a SDS is compliant. Currently, hazard classifications are performance oriented, which means hazards are evaluated on fairly vague and broad criteria. However, under the new HazCom 2012 rule, specific, detailed criteria is provided to help guide the evaluation into the classification of the chemical. In addition, classification now means that hazards are evaluated not only for existence but severity.
Currently hazards are evaluated and communicated downstream via SDSs and labels. In evaluating hazards, there is currently flexibility in the use of professional judgment to identify the most relevant hazards associated with chemicals. Under GHS standards, all hazards are to be classified, meaning there is specific detailed criteria for determining hazard classification for materials. This means there will be much less flexibility when classifying. Furthermore, GHS allows countries and agencies to adopt portions of GHS that best fit within their existing regulatory guidelines, which means classifications may not be 100 percent harmonized between countries and agencies.
Resolution #2 – Acquire, review and manage new incoming SDSs
It may sound simple, but with the high volume of new SDSs being distributed in the near future, this resolution can be difficult to achieve. In order to meet GHS compliance, you will be expected to replace your current MSDSs with SDSs when submitted by the manufacturer. To do this successfully, you will need to review the SDSs you receive to ensure new hazard information is understood and acted upon.
When inspecting the quality of a SDS, there are some requirements to keep in mind. First and foremost is the name itself. Although the terms are often used interchangeably, a material safety data sheet (MSDS) and safety data sheet (SDS) are in actuality documents with specific format and content differences. A SDS must be formatted to include 16 required sections in the specified order. Currently, OSHA does not specify how many sections or the order in which they appear on a MSDS. Under HazCom 2012, OSHA requires SDSs to be in a uniform format and include section numbers, headings and associated information.
Under the new Hazard Communication Standard (HCS), sections two and three will be swapped in the SDS format. Section two will now be the hazard(s) identification segment which includes emergency overview and required label elements incorporating signal words and pictograms, and section three will provide the composition/information on ingredients. In addition, SDSs will also need to be reclassified based upon the new GHS criteria. There are new health, physical and environmental health classifications that will need to be communicated in section two of the SDS. OSHA has stated it will not require data in sections 12, 13, 14 or 15 since other agencies regulate this information. However, it is required to have at least the heading for these sections on the SDS.
That said, you will need to choose your method for managing SDSs going forward. As with many other non-core activities, most companies outsource this function today. Current SDS software and service providers already have catalogs of materials and safety data sheets with an established process for acquiring, updating and managing SDSs.
Resolution #3 – Update workplace labels
Currently, OSHA imposes a performance-based requirement on chemical labels, so employers may choose how to convey the hazard information on the label. This allows liberties to the manufacturer, importer, and distributor on how it is displayed.
Under GHS, there is no required, standardized format; however, there are required elements. These elements include the following:
- Product identifier – this should match the product identifier on the Safety Data Sheet
- Signal word – Either use “Danger” or “Warning”
- Hazard statement – A phrase assigned to hazard class that describes the nature of the product’s hazard
- Precautionary statement – Describes recommended measures to minimize or prevent adverse effects resulting from exposure
- Supplier identification – The name, address, and telephone number of the manufacturer or supplier
- Pictogram – Graphical symbols intended to convey specific hazard information visually
Based upon the new criteria, there will only be two signal words – Danger (severe) and Warning (less severe). The use of a red border used within the pictogram is also a new change with GHS; however, an employer may choose to use a black border for workplace (or in-plant) labels only. Although GHS uses a total of nine pictograms, OSHA will only enforce the use of eight, as the environmental pictogram is not mandatory but can be used to provide additional information. It’s also worth noting that the signal word, pictogram, and hazard statement are required to be located next to each other.
Another significant change will be in the NFPA and HMIS rating systems used in labeling workplace containers. These ratings are used when transferring a chemical from its parent container to a secondary workplace container. Under GHS, the rating systems will be numerically inverse from the current system. For example, currently HMIS hazard ratings are listed in order from 0 -minimal hazard to 4 – severe hazard. Under GHS, the ratings will be 1- severe hazard to 5 – minimal hazard. Employers may continue to use rating systems such as HMIS or NFPA diamonds for workplace labels as long as they are consistent with the requirements of the Hazard Communications Standard and the employees have immediate access to the specific hazard information discussed above. Additionally, an employer using NFPA or HMIS labeling must, through training, ensure its employees are fully aware of the hazards of the chemicals used.
Resolution #4 – Train your workforce
As you are aware, the deadline to train employees on GHS has passed. However, it is required to train new employees, as well as provide training when a new physical or health hazard is introduced into the workplace. For example, if a new chemical is brought into the workplace with the same hazard classifications for which a training has been conducted, then there is no additional training required. However, if a new chemical with hazardous properties that has not been in the workplace before, then new training for those hazards must be conducted for employees who work in areas where they could be exposed.
Some of the most important changes to communicate in training will focus on how to read updated labels, how to interpret the new pictograms, and what the various signal words, hazard statements, and precautionary statements mean. For example, there may be confusion based on the GHS rating system versus traditional rating systems like HMIS or NFPA. Having a plan to communicate these hazards is essential to meeting OSHA requirements and ensuring workplace safety.
Resolution #5 – Track your progress
As with any resolution, tracking your progress is a good way to stay accountable and keep your goal top of mind. Meeting GHS compliance involves many moving parts like training as well as acquiring updated safety data sheets from your suppliers. Thankfully, there are applications to help you stay on track with your GHS goals. Tracking internal process items such as employee trainings and chemical inventories can be achieved by using training software or simple spreadsheets. However, tracking the number and percent of updated GHS SDSs from your vendors can be a little more difficult. If you are using a SDS software vendor system, be sure to ask how you can track your GHS compliant SDSs.
As 2015 begins, OHS professionals in the U.S. can anticipate the implementation of GHS as they receive new safety data sheets and labels in the months ahead. Preparing for the transition will help you achieve GHS success. In addition, there are a number of resources available to help you along the way, including the OSHA website, www.osha.gov.