After many years, the final effective completion date for the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) nears. As we know, OSHA adopted new hazardous chemical labeling requirements as a part of its revision of the Hazard Communication Standard (HCS), 29 CFR 1910.1200, bringing it into alignment with the United Nations’ GHS. These changes will help ensure improved quality and consistency in the classification and labeling of all chemicals, and will also enhance worker comprehension. As a result, workers will have better information available on the safe handling and use of hazardous chemicals, thereby allowing them to avoid injuries and illnesses related to exposures to hazardous chemicals.
Let’s look at how OSHA’s June 1, 2016, requirement actually reads. In short, OSHA says, “Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.” This final timeline requirement applies to employers, but what does it mean? Essentially it means that employers must have workplace labeling and hazard communication programs up to date as necessary (this includes having all Material Safety Data Sheet-formatted documents replaced with the newer Safety Data Sheet-formatted documents). It also states that additional training must be conducted for newly identified physical or health hazards.
On June 1, 2016, the three-year transition period ends. This transition period allowed compliance with HCS 2012, HCS 1994 or both.
The GHS label format provides detailed yet easy-to-understand guidance for application of the hazard communication elements on a label. It specifies for each hazard, and for each class within the hazard, what signal word, pictogram and hazard statement should be used. The GHS hazard pictograms, signal words and hazard statements should be located together on the label. I would encourage you to view Annex 7 of the UNECE Rev. 3 (2009) Purple Book, which explains how the GHS pictograms are expected to be proportional to the size of the label text so that generally, the GHS pictograms would be smaller than the transport pictograms.
Employers must ensure the SDSs are readily accessible to employees for all hazardous chemicals in their workplace. This may be done in many ways. For example, employers may keep the SDSs in a binder or on computers – as long as the employees have ready access to the information without leaving their work area when needed, and a backup is available for immediate access to the SDS in the case of a power outage or other emergency situations. Furthermore, it’s a good time to remember that employers should designate a person(s) responsible for obtaining and maintaining the SDSs. If the employer does not have an SDS, the employer or designated person(s) should contact the manufacturer to obtain one.