Six Steps to Understanding HazCom GHS Compliance
A fast approaching deadline means all chemical exposed workers must be trained in The Revised Hazard Communications Standard Safety Data Sheets (HazCom GHS) in order to be OSHA compliant. Most of these workers aren’t in the chemical industries. They are carpenters who handle adhesives, tower workers who handle paints, and many more trades.
The magnitude of the task is vast – some 5 million employers must train 43 million workers to the new OSHA standard by deadline! To help you understand the new regulations, LBA University™ offers this six-step guide on HazCom GHS compliance.
1. What is the new GHS OSHA standard and when does it begin?
The Globally Harmonized System (GHS) is a globally standardized approach to label elements and safety data sheets. The basis of GHS encompasses practices utilized by major existing systems around the world, including OSHA’s Hazard Communication Standard and the chemical classification and labeling systems of other U.S. and international agencies.
The new standard provides harmonized classification criteria for health, physical, and environmental hazards of chemicals. It also includes standardized label elements that are assigned to these hazard classes and categories, and it provides the appropriate signal words, pictograms, and hazard and precautionary statements to convey the hazards to users. A standardized order of information for safety data sheets is also provided.
OSHA is adopting the GHS. This means the Hazard Communication Standard (HCS) is being modified. The original standard is performance-oriented, allowing chemical manufacturers and importers to convey information on labels and material safety data sheets in whatever format they choose. The GHS utilizes a more standardized approach to classifying the chemical hazards and conveying the information.
The new GHS OSHA standard will include detailed criteria for determining what hazardous effects a chemical poses, as well as standardized label elements assigned by hazard class and category. The safety data sheet requirements establish an order of information that is standardized. Adoption of the GHS in the U.S. and around the world aims to improve the understanding of chemical information received from other countries. The goal is to elevate the effective and efficient access to information by all those exposed to chemicals, including emergency responders.
The revised HazCom GHS will be phased-in using several key compliance deadlines in the U.S. The table below outlines these deadlines and the actions necessary for compliance.
|Compliance Effective Date||Requirement(s)||Compliance Responsibility|
|December 1, 2013||Train employees on the new label elements and safety data sheet (SDS) format.||Employers|
|June 1, 2015
December 1, 2015
|Compliance with all modified provisions of this final rule, except:The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label||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 to the effective completion dates noted above||May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both||Chemical manufacturers, importers, distributors, and employers|
Three key compliance facts:
- Employers must provide the appropriate HazCom GHS compliance training prior to the compliance effective date.
- Employers are required to be in compliance with either the existing HCS or the revised HCS, or both.
- OSHA understands that there will be a period of time where labels and SDSs under both standards will be present in the workplace. This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.
The bottom line for meeting compliance standards for the December 1, 2013 deadline is that employers must train employees on the new label elements, which include pictograms, hazard statements, precautionary statements, signal words and the new SDS format. This training must take place prior to the effective date.
2. How has the standard changed from the old HazCom?
Three major areas of change:
- Hazard definitions have been changed to provide specific criteria for hazard classification of health and physical hazards, as well as classification of mixtures.
- Chemical manufacturers and importers will be required to provide labels that include a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
- Safety Data Sheets will now have a specified 16-section format.
3. What are the details of the new HazCom GHS pictograms and labels?
Under the current HazCom, the label preparer must provide the identity of the chemical, and the appropriate hazard warnings. This may be done in a variety of ways, and the method to convey the information is left to the preparer. Under the revised HazCom, once the hazard classification is completed, the standard specifies what information is to be provided for each hazard class and category.
Labels will require four elements:
- Pictogram: A symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the new HazCom.
- Signal words: A single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for less severe hazards.
- Hazard Statement: A statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
- Precautionary Statement: A phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling of a hazardous chemical.
There are eight required HazCom GHS pictograms and they must be displayed with the symbol in black and bordered in red as illustrated below:
GHS Pictogram Chart
*The environmental pictogram is not required, because environmental hazards are not within OSHA’s jurisdiction.
Note: HazCom GHS will require chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical to revise the labels for the chemical within six months of becoming aware of the new information. Labels on containers of hazardous chemicals shipped after that time must contain the new information. If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.
4. How will HazCom GHS change the Safety Data Sheet (SDS)?
The information required on the safety data sheet (SDS) will remain essentially the same as that in the current standard known as HazCom 1994. What will change is the format for how that information is displayed. The revised Hazard Communication Standard for the SDS format is the same as the ANSI standard format which is widely used in the U.S. and is already familiar to many employees.
The SDS format will require 16 sections with specific headings in a specific order:
- Section 1. Identification
- Section 2. Hazard(s) identification
- Section 3. Composition/information on ingredients
- Section 4. First-Aid measures
- Section 5. Fire-fighting measures
- Section 6. Accidental release measures
- Section 7. Handling and storage
- Section 8. Exposure controls/personal protection
- Section 9. Physical and chemical properties
- Section 10. Stability and reactivity
- Section 11. Toxicological information
- *Section 12. Ecological information
- *Section 13. Disposal considerations
- *Section 14. Transport information
- *Section 15. Regulatory information
- Section 16. Other information, including date of preparation or last revision
*The contents of sections 12-15 will not be enforced, but the section headings must be included. The contents of these sections are not under OSHA’s jurisdiction.
5. Who is affected and what are the benefits and cost?
According to estimates published by OSHA, over 5 million workplaces and 43 million employees in the U.S. would be affected by HazCom GHS. The standard for determining what facilities are affected is relatively straightforward. The United States Department of Labor states that any establishment where employees “could be exposed to hazardous chemicals” is required to comply with OHSA HazCom GHS.
OSHA has projected several benefits from the revised HCS. The agency said that on an annual basis it will result in the prevention of 43 fatalities and 585 injuries and illnesses, 203 lost-workday injuries and illnesses, and 64 chronic illnesses. This translates into preventing 318 lost-workday injuries and illnesses. OSHA estimates that the monetized value of this reduction in occupational risks is an estimated $250 million a year.
OSHA estimates substantial residual financial benefits as well. They believe that productivity improvements for health and safety managers and logistics personnel will result in savings of $475.2 million. The total cost for implementing and maintaining HazCom GHS is estimated at $201 million a year on an annualized basis for the entire U.S.
6. How to stay current on the latest training requirements?
As with any government mandated safety requirement, it is subject to change. HazCom GHS is no exception. It is expected that the GHS will certainly issue changes over time that may be adopted on a two year cycle.
Updates in the future could include:
- Technical updates for minor terminology changes
- Direct Final Rules for text clarification
- Notice and Comment rulemaking for more substantive or controversial updates such as additional criteria or changes in health or safety hazard classes or categories. Visit www.osha.gov/dsg/hazcom for detailed GHS HazCom information.
LBA University™ is happy to serve as a resource for your questions concerning HazCom GHS. Bryan Dixon, LBAU’s course director, is an OSHA-authorized safety instructor with two decades of industrial, construction and fire safety training experience. LBAU offers an economical HazCom GHS training course online. Custom training options for employers are available on location, or at the LBA University Training Center in Greenville, NC.
“The Dec. 1 GHS deadline is just the first in a series of rollouts of the new GHS standard by OSHA,” said Dixon. “I would expect the agency to pay very close attention to compliance related issues as this new system is implemented.”
Contact Bryan for a no obligation consultation about your professional safety training needs. He can help you determine if HazCom GHS training is needed and the best approached to achieve cost effective and efficient training. Contact Bryan at: firstname.lastname@example.org or 252-757-0279.
About LBA Group Inc.
LBA Group, Inc. has 50 years of experience in risk management, design, and integration of industrial and wireless telecommunications infrastructure assets, worldwide. It is comprised of the professional technology consultancy Lawrence Behr Associates, Inc. ; LBA University, Inc. providing on-site and online professional training; and LBA Technology, Inc., a leading integrator of radio frequency systems, lightning protection, and EMC equipment for broadcast, industrial, and government users. The companies are based in Greenville, N.C., USA.
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