GHS

Getting Your Haz Com Program Ready for GHS

Date First Published on SafetySmart Compliance: March 26th, 2012
Topics: GHS Transition | HazCom |


Who Should Read This:
This article is for employers that use, handle or store hazardous chemicals and are covered by the OSHA Hazcom standard; it’s not for companies that manufacture, import or distribute such chemicals. 

Now that OSHA finally issued the Final GHS Rule, you face the task of making the transition to GHS.  A key task in the transition will be to go through your current workplace Hazard Communication Program (HCP) and revising it to meet GHS requirements. Here’s what you have to do and when.

  1. MAKE SURE YOU HAVE AN HCP   

Current Law: The Hazcom standard (Sec. 1910.1200(e)(1)) requires employers to have a written HCP for each workplace where hazardous chemicals are used, handled or stored.

GHS Changes: The Final GHS Rule doesn’t change this requirement.

What to Do: If you need an HCP now, you’ll also need one for GHS. But you will have to tweak your current HCP. Keep reading. . .   

  1. MAKE HCP ACCESSIBLE

Current Law: You must make the written HCP “available upon request” to employees, their designated representatives and OSHA officials (Sec. 1910.1200(e)(5)).

GHS Changes: This requirement isn’t changing.

What To Do: Keep providing those same groups access to your HCP if they request it the way you have in the past.

  1. EXPLAIN LABELING IN YOUR HCP

Current Law: You must ensure that containers of hazardous chemicals have labels, tags or other markings identifying the chemical and warning about the hazards it poses.  The HCP must explain the methods you use to comply with these labeling requirements.

GHS Changes: GHS doesn’t affect the obligation to describe labeling methods in the HCP. But it does change the workplace labels themselves—both in terms of format and information they must list.  (Click here to find out about the new GHS label requirements.)

What To Do: You must ensure that every container of hazardous chemicals has one of those newfangled GHS labels by June 15, 2016. That means you may have to revise the part of your HCP that describes your labeling methods to comply with the new requirements:

You will have to revise the HCP if it cites or summarizes specific parts of the current Hazcom labeling standard that GHS changes :

Example of HCP Language that DOES Have to Be Revised

ABC Company will ensure that each container of hazardous chemicals is marked with a workplace label listing:

  1. The identity of the hazardous chemical;
  2. Appropriate hazard warnings; and
  3. Name and address of the chemical manufacturer, importer or other responsible party.

    You won’t have to revise the HCP if the labeling language is generic and doesn’t specifically list or cite the label requirements affected by GHS:

Example of HCP Language that DOESN’T Have to Be Revised

ABC Company will ensure that each container of hazardous chemicals is marked with a workplace label listing all of the information required by OSHA.

  1. EXPLAIN MSDS SYSTEM IN HCP

Current Law: You must keep in your workplace Material Safety Data Sheet (MSDS) for each hazardous chemical present and make MSDSs available to employees. The HCP must explain the methods you use to comply with the MSDS requirements.

GHS Changes: GHS doesn’t affect the obligation to keep an MSDS binder and describe your MSDS system in the HCP. But it does change the MSDS itself—which, under GHS, will be called SDSs, or Safety Data Sheets. More significantly, the new SDS will have a different format and list different information. (Click here to find out about the new SDS requirements.)

What To Do: By June 1, 2016:

  • Get an SDS for each hazardous chemical from your supplier;
  • Revise your MSDS binders and/or electronic systems by removing the old MSDS and replacing it with the new SDS
  • Adding SDSs to your binder or system for chemicals that didn’t need an MSDS under the old rules but do require one under GHS
  • Make cosmetic changes to the HCP: Change “MSDS” to “SDS”
  • Make substantive changes to the HCP to the extent it cites or mentions specific MSDS requirements being changed by GHS.

 

  1. ADDRESS HAZARDOUS CHEMICAL TRAINING & INFORMATION IN HCP

Current Law: You must provide employees “effective information and training” on hazardous chemicals in their work area. The HCP must describe what you do to comply with these requirements .  

GHS Changes: GHS doesn’t change the requirement of listing your information and training methods in the HCP. But it does change the substance of the training required.  First and foremost, it requires that all employees be trained how to use the new GHS labels and SDSs by Dec. 1, 2013. It also makes some minor changes affecting when training must be provided and what it must cover:  

CURRENT RULE

GHS RULE

New training required when new “physical or health hazard” introduced

New training required when new “chemical hazard”  introduced

Employees must be trained about “physical and health hazards” of chemicals in the work area

Employees must be trained about “physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified” of chemicals in their work area

What To Do: Make the following modifications to your HCP:

  • Specify that all employees will receive information and training on how to use GHS labels and SDSs;
  • Indicate that new training will be provided upon the introduction of new “chemical hazards” into the workplace for which the employee hasn’t been trained; and
  • Indicate that employees will be trained about not just physical and health hazards posed by chemicals in the work area but also simple asphyxiation, combustible dust, pyrophoric gas and other hazards not otherwise classified.
  1. INCLUDE HAZARDOUS CHEMICALS INVENTORY IN HCP

Current Law: The HCP must list the hazardous chemicals known to be present at the site, i.e., the chemicals for which an MSDS is required.  

GHS Changes: GHS doesn’t change the requirement that the HCP include a hazardous chemical inventory. But it does render your current inventory obsolete. Explanation: GHS requires chemical manufacturers, importers and distributors to re-classify their products and prepare labels and SDSs by June 1, 2015. Some of the chemicals that get re-classified could be ones you list in your inventory—or don’t list:   

Example

ABC Company uses Chemical X. In the current Hazcom system, Chemical X isn’t classified as hazardous. In 2015, the manufacturer of Chemical X re-classifies the product as hazardous. Result: ABC Company now needs to get an SDS and list Chemical X on its hazardous chemicals inventory.

What To Do: Make sure you get GHS labels and SDSs for all hazardous chemicals from your supplier by June 1, 2015. You’ll then have until June 1, 2016, to revise your hazardous chemicals inventory to ensure it reflects GHS re-classification. To do this, you’ll have to confirm that:

  • Chemicals you’re using that aren’t currently classified as hazardous haven’t been re-classified as hazardous—if they have been, you’ll need to add them to your inventory
  • Hazardous chemicals you’re using are still hazardous—if they’ve been re-classified as non-hazardous, you’ll have to remove them from your inventory; and
  • Hazardous chemicals are still in the same hazard categories, e.g., flammables are still considered flammables and haven’t been re-classified as oxidizers.

 

  1. DESCRIBE NON-ROUTINE TASK WARNING METHODS IN HCP

Current Law: The HCP must describe the methods you use to inform employees of hazards posed by non-routine tasks, e.g., cleaning reactor vessels.

GHS Changes: The Final GHS Rule doesn’t change this requirement.

What To Do: You don’t have to modify this part of your HCP—except where necessary to reflect GHS terminology, e.g., changing references to “MSDS” to “SDS.”  

  1. DESCRIBE CHEMICALS IN UNMARKED PIPES WARNING METHODS IN HCP

Current Law: The HCP must explain how you notify employees of hazards associated with chemicals contained in unlabeled pipes in their work areas.  

GHS Changes: The Final GHS Ruled oesn’t change this requirement.

What To Do: You don’t have to modify this part of your HCP—except where necessary to reflect GHS terminology, e.g., changing references to “MSDS” to “SDS.”  

  1. DESCRIBE CONTRACTOR EMPLOYEE SDS ACCESS IN HCP

Current Law: Your HCP must explain how you provide employees of contractors, subcontractors  and other employers at your site  (which we’ll refer to as “contractor employees”) access to the MSDSs of hazardous chemical to which they’re exposed.  

GHS Changes: The Final GHS Rule doesn’t change this requirement.

What To Do: As long as you continue to rely on the same system of MSDS/SDS access for contract employees, you don’t have to change this part of your HCP—other than to change “MSDS” references to “SDSs.”

  1. CONTRACTOR EMPLOYEE PRECAUTIONARY MEASURES NOTIFICATION IN HCP

Current Law: Your HCP must describe the methods of notifying contractor employees of precautionary measures that may be required during normal work operations and in response to emergencies.

GHS Changes: The Final GHS Rule  doesn’t change this requirement.

What To Do: As long as you continue to rely on the same system as before, you don’t have to change this part of your HCP—other than changes in terminology.  

 
 
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