What steps do I need to take to be compliant under the new Hazard Communication Standard?
Responding is Danielle Gallo, global product manager, Brady Worldwide Inc., Milwaukee.
The recent update to OSHA’s Hazard Communication Standard (CFR 1910.1200) changes the requirements for chemical labeling and mandatory employee training. The new Globally Harmonized System creates a universal standard to help keep workers safe and informed about chemical hazards. Because Hazcom is already one of the most frequently violated OSHA standards, it’s essential to know exactly what GHS is and how it affects your business.
With the June 1, 2016, full compliance deadline creeping closer, now is the time for companies affected by OSHA’s Hazcom standard update to be proactive. Compliance often is a struggle when employers lack written programs, fail to include enough information in written programs or don’t provide proper training.
Learning about GHS
Throughout the process of aligning with the new GHS standard, make sure your written Hazcom program is updated and reflects any internal and external changes. Learn the ins and outs of GHS by familiarizing yourself with the new label format, the 16 elements of a Safety Data Sheet, and the GHS pictogram symbols and their various hazard classes.
If you have not done so already, separate SDS and the previous Material Safety Data Sheet binders and sheets. This will help you stay organized when you re-label chemicals with SDS information and determine which sheets have not been received. As new chemicals enter your facility, be sure to note any hazards identified on SDS and potential personal protective equipment changes.
Dec. 1, 2013, was the deadline for training on the new SDS elements and format, label elements, pictograms, and overall changes to the Hazcom standard. With this date behind us, it’s important to continue to keep employees educated with re-training on pictograms, labels and SDSs. It also is useful to provide visuals – such as posters, signs and wallet cards – to keep the GHS update top-of-mind.
June 2015 deadline
By June 1, 2015, all chemical manufacturers, importers and distributors must reclassify chemicals and send SDSs and labels in the new GHS format. By this deadline, it’s important to identify additional labeling needs, purchase GHS labeling supplies and implement new labeling procedures based on SDSs and archive old MSDSs. Until conversion is complete, continue to train employees on both the new GHS standard and your existing Hazcom program.
December 2015 deadline
The Dec. 1, 2015, deadline is when distributors should send only updated SDSs and labels. This is the time to review and ensure all MSDSs have been converted to the SDS format. It’s also important to audit all containers to ensure they reach compliance under the new regulations and establish a policy to control improperly labeled containers.
By reaching these milestones along the way, you will be prepared for full compliance by June 1, 2016. Maintaining compliance is easily done by keeping employees informed through consistent communications, up-to-date policies and annual training.
Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.