Want to know if your employees have understood the new GHS for chemical labelling?
Here’s a fun way for them to review the new regulations as well as take a fun quiz that’ll show how much (or how little) they really know.
Provided by Jeff Dalto from Convergence Training this online presentation combines information and fun.
Give it a try!
In a letter dated June 13, 2014 the US Department of Labor, OSHA clarified it’s position regarding the new GHS for classification of chemical stating that “employers
may, but are not required to, contact manufacturers or distributors of products they have previously ordered to request new SDSs“.
What OSHA is saying is that if you have chemicals in your facility that date back before the implementation of GHS, the MSDS sheet is all that is required, OSHA will not issue a citation. If, however the chemical was purchased or brought in after the implementation of GHS than it should have come with the new SDS rather than the MSDS and that SDS is what needs to be on file.
The letter of clarification was issued in response to a question submitted to OSHA. The full letter can be viewed here.
OSHA is expected to update its Hazard Communication standard to include the new Globally Harmonized System of Classification and Labeling of Chemicals.
Download this free whitepaper to learn:
- What the GHS is and why it’s needed
- Who the GHS will affect
- How the GHS will change the way we communicate chemical hazards
- Why the GHS will benefit you and your employees
- And much more!
The Free whitepaper is available from the Brady website here.
Maine Community College has put together a video that you can use for yourself and your employees to help get them up to date on the new GHS standard due to take effect in Dec. of this year.
If PowerPoint is more your cup of tea, than there’s one available from the State of Michigan at http://search.michigan.gov/search?affiliate=mi-som&query=miosha_ghs#!
Unlike in the movies where exposure to hazardous chemicals result in mutation that give people superhuman abilities and powers, in real life exposure to hazardous chemicals results in adverse health effects (some of which can take years to show up) and, in many cases, death.
Because of this a massive undertaking entitled the “Globally Harmonized System of Classification and Labeling of Chemicals” (GHS) has been under way since the middle of last year (March 2012).
Essentially what GHS is doing is to replace the MSDS with a standardized system that applies across the different countries from which chemicals are being imported and exported to.
Feeling a little overwhelmed? Not sure where to get started?
The OSHA Hazard Communication page, dedicated to GHS will get you well on your way and should answer most, if not all of your questions.
You’ll find comparisons sheets between HazCom 1994 and Hazcom 2012, OSHA Briefs, Fact Sheets, Quick Cards, Downloadable Pictograms and a whole lot more.
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We’ve been talking about the GHS for the past three posts. Now that we’ve learned a little more about what it is, why it’s needed and what needs to be done to comply with it it’s time to actually start making the changes and doing the training that is required.
Fortunately, help is available. I’ve located a site for you where you can download a complete GHS Compliance kit that gives you everything you need.
GHS PowerPoint presentation for training on the GHS
GHS Purple book that contains links for downloading the following pdfs:
The Free GHS Compliance Kit is available through http://www.ghskit.com/
You’ll have to sign up and they’ll send you a link to download it.
So far, in part 1 we looked at what the GHS was and why OSHA adopted it. Then, in part 2 we looked at the timeline for implementation as well as what the major changes involved are. Today, in our final post on the GHS we are going to look at a few miscellaneous issues involved with the GHS as well as talk about one or two major ommissions.
What the GHS IS NOT changing
A couple of things that are not changing (This is a good thing), is the fact that TLVs (Threshold Limit Values) and PELs (Permissible Exposure Levels) will remain on all documentation. The reason I believe this to be a good thing is because these are numbers that we’ve grown very used to in the safety industry and users and manufacturers alike look for them to decide how safe they are based on exposure to the said chemical.
In addition to the TLV and PEL, OSHA is keeping the IARC (International Agency for Research on Cancer) as well as the NTP (National Toxicology Program) classifications. This should make it clear whether or not the chemical is a known carcinogent and allow users to make educated choices about the level of exposure to chemicals that are known or suspected of causing cancer.
What GHS does not cover
Unfortunately, OSHA still hasn’t dealt with issue of combustible dust. We’ve talked before about this inexplicable inactivity on the part of OSHA and apparently it continues with GHS. This from the OSHA website on this matter:
OSHA has not provided a definition for combustible dust to the final HCS given ongoing activities in the specific rulemaking, as well as in the United Nations Sub-Committee of Experts on the GHS (UN/SCEGHS). However, guidance is being provided through existing documents, including the Combustible Dust National Emphasis Program Directive CPL 03-00-008, which includes an operative definition, as well as provides information about current responsibilities in this area. In addition, there are a number of voluntary industry consensus standards (particularly those of the NFPA) that address combustible dust.
In the final HCS, combustible dust hazards must be addressed on labels and SDSs. Label elements are provided for combustible dust in the final HCS and include the signal word “warning” and the hazard statement “May form combustible dust concentrations in the air”.
For chemicals in a solid form that do not present a combustible dust hazard, but may form combustible dusts while being processed in normal downstream uses, paragraph (f)(4) of the HCS allows the chemical manufacturer some flexibility in labeling requirements. The manufacturer or importer to may transmit the label to the customer at the time of the initial shipment, but the label does not need to be included with subsequent shipments unless it changes. This provides the needed information to the downstream users on the potential hazards in the workplace, while acknowledging that the solid metal or other materials do not present the same hazards that are produced when these materials are processed under normal conditions of use.
While any effort is welcome, this does not seem to go far enough and until it is properly addressed, further deaths and injuries will be inevitable.
The bottom line on the GHS is that an estimated 5 million places of business and some 46 million workers in the US will have a clear, more manageable way to track, catalog and understand the health and environmental hazards associated with the chemicals that they are using. While the initial cost of implementing GHS runs into the hundreds of millions, ultimately the saving of lives, health care expenses, trying to “interpret” and “translate” the different standards from different countries will make the cost worth it. It is an issue that has needed to be addressed for too long. OSHA estimates that this change will prevent 43 and almost 600 injuries each year. That’s substantial. While the issue of combustible dust remains a disappointment, the implementation of the GHS is monumental in helping promote better safety regarding the use of various chemicals in the workplace.
Yesterday we defined the GHS and explained why OSHA decided to adopt it in Understanding GHS (Part 1). Today we are going to look at the timeline for phasing in GHS as well as understanding what the major changes are going to be.
GHS phase-in timeline
December 1, 2013 – employees need to have completed the training on the new labels and MSDS.
June 1, 2015 – Compliance with all modified provisions for anything being produced by manufacturers, importers and distributors of chemicals.
December 1, 2015 – Nothing is shipped without the new GHS labels and MSDS (the period between June 1 and December 1 is intended to allow for the clearing out of old stock that might not yet have the new GHS data).
June 1, 2016 – Every place of business that uses chemicals should be compliant with GHS.
Hazard Classification – This is perhaps the big change. The GHS establishes specific criteria for the classification of health hazards. It gives clear hazard classes and categories that clearly outline the severity of the effect.
Labels – The labels will have signal words, pictograms and hazard statements for each hazard class and category. There are nine pictograms and hazards. The following table from the OSHA website that outlines the new GHS breaks it down best:
HCS Pictograms and Hazards
Target Organ Toxicity
Emits Flammable Gas
|Irritant (skin and eye)
Acute Toxicity (harmful)
Respiratory Tract Irritant
Hazardous to Ozone Layer
|Gases under Pressure||Skin Corrosion/ burns
Corrosive to Metals
|Flame over Circle
|Skull and Crossbones
|Oxidizers||Aquatic Toxicity||Acute Toxicity (fatal or toxic)|
Safety Data Sheets – Finally, the safety data sheet will have 16 specific sections to it. These are:
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
Check back on Monday when we’ll continue looking at the GHS.