Final GHS Deadline Is Almost Here!

It feels like we have been talking about the enacting of the Globally Harmonized System (GHS) for years, probably because we have been discussing the different aspects and implementation plans since it came out in 2012. The last deadline for compliance with this regulation is almost here. With the three-year transition period for full implementation of this regulation ending on June 1, 2016, this standard and its components should be at the fore front of our minds.

For those that may be unaware, the GHS standard is an update to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication (HazCom) regulation 29 CFR 1910.1200. This new standard was set up to ensure improved quality and consistency in the classification and labeling of all chemicals in the workplace, as well as enhance worker comprehension.  According to this OSHA standard, “employers should update alternative workplace labeling and hazard communication programs as necessary, and provide additional training for newly identified physical or health hazards.”

What this standard is essentially saying is that all workplace labels and hazard communication programs should be revised or updated to comply with the specifications outlined in the new standard. To better explain what is required by this rule, here are some tips for ensuring that your facility is in compliance:

1)      Prepare a Written Hazard Communication Program

A written HazCom program should be prepared, specifying how HazCom will be designed and implemented at your facility. This program should include data and chemical management, training, and a list or inventory of all hazardous chemicals in the workplace.

2)      Assign a Program Manager

Make sure that someone is responsible for coordinating implementation with this rule. It is important that both management and employees are aware of who is in charge of this program and how they can get information and help with the implementation.

3)      Safety Data Sheet (SDS) Management

By June of this year, all employers will need to maintain an SDS (formerly Material Safety Data Sheet – MSDS) for each hazardous chemical in the workplace. Employers may keep the SDSs in a binder or on a computer, as long as employees have ready access to the information. As part of complying with this part of the rule, all MSDS should be updated to follow the SDS format.

4)      Ensure Containers Are Properly Labeled

It is important to walk through your facility and confirm that labels on all shipped and workplace containers are properly labeled with the label specifications outlined in the regulation. To help with this, ensure that your distributors are sending properly labeled containers to your facility. Some of the items that are required to be on a label include pictograms, signal word, hazard statement, precautionary statements, etc.

5)      Train Employees

The training requirements of the updated standard were the first part of the rule to have a compliance deadline, which was December 2013. The regulation requires all current employees to be trained on the hazards of the materials they work with, requirements of the standard, label requirements, SDS components and layout, etc. This training should occur before initial assignment and when new hazards are introduced to the workplace.

Please make sure that your facility is following the guidelines set by the updated HazCom regulations. It is imperative that all of your employees, both permanent and temporary, are properly trained and comprehend OSHA’s requirements and updates with this standard. As mentioned in Conversion Technology Inc.’s (CTI) January Newsletter, with the deadline falling in 2016, this will be a hot button violation that OSHA inspectors are expected to focus on.

Contact CTI if you have any questions on how to ensure that your facility maintains compliance with this OSHA standard, or if you would like to discuss HazCom training, customized written program, chemical inventory, etc.

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