September is here. This means that employers only have 3 months before the first deadline for the new Hazard Communication (HazCom) standard, GHS, hits us. With that in mind, we thought it would be a good time to quickly summarize some of the key requirements of the standard for those who are still unsure about it.
So, first off, what is GHS? GHS stands for the Globally Harmonized System for the Classification and Labeling of Chemicals. It’s actually a standard adopted within the United Nations and many UN member countries, including the United States, have pledged to adopt it. OSHA formally adopted GHS last year (2012). GHS is a big system though, covering more than just occupational safety and health, so it’s possible (if not likely) that other US agencies will adopt portions of GHS for their jurisdictions (e.g. EPA, Consumer Product Safety Commission).
GHS affects three big areas – Classification, labeling, and (M)SDSs. Lets look at each. As for classification of hazardous substances, GHS changes the way that OSHA defines “hazards.” The basic concepts will be the same but the specifics will change. For example, the definition of a “flammable liquid” is basically the same – a chemical that can readily catch fire. However, the specific definition will change, from a liquid with a flashpoint less than 100 degrees F, to one with a flashpoint less than 140 degrees F. There are also some specific chemical hazards called out that many are not familiar with, such as “sensitizers.” Employees will have to get used to some of these new terms and definitions, especially if they work with these types of chemicals.
One area of GHS classification that has had much attention and some controversy is the use of categories for some of the hazards to denote how hazardous the material is. For example, acute toxicity has 5 hazard categories, with category 1 being the most toxic and category 5 being the least. Those who’ve been in the hazmat industry for a while will note that this is completely the opposite of the NFPA diamond, which notes hazards from 0 to 4, with 0 meaning no hazard and 4 the highest hazard. Unfortunately employees will just have to get used to the new system as its unlikely that either GHS or NFPA will change their respective systems anytime soon.
The second area that you’ll need to look at for GHS is the new labeling. Labels will have a specific format with required pictograms and wording. Now labels will still look somewhat different from one manufacturer to another. But the overall content should be very consistent, making the system much easier to use for identification of hazards. For more information and to see some examples of new labels, here’s a link to the OSHA site.
Finally, the new GHS standard took the “M” out of “MSDS.” That’s right we now call them SDSs (Safety Data Sheets). However, in exchange for giving up the “M” we got a new standardized format for SDSs. MSDSs are notoriously for being hit or miss sometimes. You’ll find some manufacturers do a great job with their MSDSs and others not so much. Plus the look and feel between MSDSs can be so different that it makes it hard to interpret them. This will all change under the SDSs. There will still be some variability and some bad SDSs but those should be the minority. SDSs will now have a required format with required wording and required sections. For example, if you want to know the flashpoint for the chemical, just look in section 9 of the SDS. Section 8 will have your PPE info. Section 5 will let you know which fire extinguisher to use. You’ll note that some MSDSs use a very similar format already, but not all. After GHS implementation all should have this format, making it easier to find the information you need.
Last, but certainly not least, as part of the adoption of GHS OSHA gave employers a timeline that they must follow to ensure they stay compliant. The timeline is as follows:
- By December 1 of this year, all employers covered by the HazCom standard must train their employees on the new labels and SDSs. (That’s less than three months from now!)
- By 2015 all manufacturers and distributors of chemicals in the US must be in compliance with GHS. This means classification, labeling, and SDSs must all be compliant.
- By June 2016 all employers must have their alternative workplace labels (e.g. secondary labeling) compliant with the GHS standard. Primarily this will include classifying chemicals and ensuring that labels reflect any new classification. New training may also be required for newly identified hazards.
Now, we’ll be the first to say that its very possible that OSHA pushes back these compliance dates, given how much work everyone has to do to get into compliance. However, we do not recommend that you bank on OSHA pushing back the dates. This means you’ll need to get to work soon to start the compliance process. If you have questions about it let us know!