Blog | Fauske and Associates, LLC

No Chemical Left Behind: Your GHS/HazCom Compliance Roadmap

Written by AnnMarie Fauske | Sep 17, 2014 4:10:00 PM

We have the pleasure of attending the National Safety Council Congress & Expo in San Diego this week (booth #3963).  Among the many great topics is the one headlined here. With ever changing regulation and deadlines, customers often ask about the future of their chemical requirements.  So, let’s revisit:

According to the 2012 changes to OSHA's Hazard Communication Standard (29 CFR 1910.1200), regulations bring the U.S. into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), improving safety and health protection for America's workers. These new revisions were and are expected to prevent injuries and illnesses, save lives and improve trade conditions for chemical manufacturers. The Hazard Communication Standard in 1983 gave the workers the 'right to know,' but the new Globally Harmonized System gives workers the 'right to understand.'

The new Hazard Communication Standard still requires chemical manufacturers and importers to evaluate the chemicals they produce or import and provide hazard information to employers and workers by putting labels on containers and preparing safety data sheets. However, the old standard allowed chemical manufacturers and importers to convey hazard information on labels and material safety data sheets in whatever format they chose. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets.

Major Changes to the Hazard Communication Standard:

  • Hazard Classification - Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
  • Labels - Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
  • Safety Data Sheets - The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
  • Information and Training - To facilitate understanding of the new system, the new standard required that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

What You Need to Do and When:

  • Chemical Users - Continue to update safety data sheets when new ones become available, provide training on the new label elements and update hazard communication programs if new hazards are identified.
  • Chemical Producers - Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets.

Effective Completion Date

Requirement(s)

Who

 December  1,  2013

 Train employees on the new label elements and SDS  format.

 Employers

 June 1,  2015

 December  1,  2015

 Comply with all modified provisions of this final rule  including reclassifying chemicals, send SDS & Labels in  GHS  format, except:

 Distributors may ship products labeled by manufacturers  under the old system until December 1, 2015.

 Chemical  manufacturers,  importers,  distributors and  employers

 June 1,  2016

 Update alternative workplace labeling and hazard  communication program as necessary, and provide  additional  employee training for newly identified physical  or health hazards.

 Employers

 Transition  Period

 Comply with either 29 CFR 1910.1200 (this final  standard), or the current standard, or both.

 All chemical  manufacturers,  importers,  distributors and  employers

As the next deadline approaches, be sure to record your progress, especially on employee training:

  • Compare old safety data sheets to new one
  • Note any new hazards on SDSs requiring new employee training
  • Secure missing safety data sheets and archive older versions
  • Update written HazCom program
  • Re-label secondary containers (if necessary) in GHS format
  • Train employees on new hazards
  • Meet  Emergency Planning and Community Right-To-Know-Act EPCRA/SARA reporting obligations
  • Stay current on GHS going forward

Here are two common questions customers ask:

Does GHS concern the Transportation of Dangerous Goods or Hazardous Materials?

No, it is a workplace rule, although some of the classification changes, for flammables, toxics and environmental hazards have been somewhat aligned in the regulations 

What are the implications of GHS on my MSDSs?

GHS system has revised Safety Data Sheet (SDS), or MSDS, requirements. 
GHS 16-section format for the SDS is as follows:

  1. Identification
  2. Hazard(s) Identification
  3. Composition/information on ingredients
  4. First-aid measures
  5. Fire-fighting measures
  6. Accidental release measures
  7. Handling and storage
  8. Exposure controls / personal protection
  9. Physical and chemical properties
  10. Stability and reactivity
  11. Toxicological information
  12. Ecological information
  13. Disposal considerations
  14. Transport information
  15. Regulatory information
  16. Other information

If you are at the NSC Expo today, stop by our booth #3963 before it closes!   For answers to more questions regarding your hazardous chemicals/process safety testing to comply with GHS, please contact Jeff Griffin, griffin@fauske.com, 630-887-5278.  WWW.Fauske.com