GHS

GHS Compliance Plan: 25 Steps to Compliance

Date First Published on SafetySmart Compliance: June 18th, 2012
Topics: GHS Transition | HazCom |

Globally Harmonized System MSDS to SDSYou’re probably going to be spending a lot of time dealing with GHS compliance over the next 4 years. Here’s a look at what GHS requires and a 25-step plan you can use to ensure compliance by the June 1, 2016 deadline.

THE GHS LAW

The OSHA GHS rule, which took effect on May 25, 2012, is not a new standard but changes to the existing Hazard Communication standard, or Hazcom, which protects workers from exposure to hazardous chemicals.

What Is GHS All About?

The reason OSHA changed Hazcom was to bring US rules into line with the global system created by the UN. GHS, which is short for “Globally Harmonized System” is designed to ensure that all countries around the world have uniform workplace hazardous chemical safety rules. (Click here for general information about GHS and why OSHA adopted it.)

Who Does GHS Affect?

GHS affects 2 groups:

  1. Companies that manufacture or import hazardous chemicals; and
  1. Downstream employers that acquire these chemicals from an outside supplier (as opposed to manufacturing or importing them themselves).

This Compliance Plan is for the latter group.

How Does GHS Change Hazcom?

Hazcom is designed to ensure that workers know about the hazards of the chemicals they work with. GHS doesn’t change the philosophy or fundamental elements of the Hazcom system—classification of chemicals according to the hazards they pose and use of Material Safety Data Sheets (MSDSs), workplace labels and safety information and training to ensure workers’ “right to know.”  But it does change some of the ways the system operates.

The 5 Phases of GHS Compliance

  1. Ensure that workers get GHS training;
  2. Replace current Hazcom workplace labels with new GHS labels (Deadline: June 1, 2016);
  3. Replace current Material Safety Data Sheets (MSDSs) with Safety Data Sheets (SDSs) (Deadline: June 1, 2016);
  4. Revise their current written Hazcom program to meet GHS requirements (Deadline: June 1, 2016); and
  5. Revise other chemical safety programs affected by GHS (Deadline: June 1, 2016).

PHASE 1: Provide GHS Training (Steps 1 to 6)

Overview: The first deadline was to ensure that workers exposed to hazardous chemicals get GHS safety training and information by December 1, 2013.

 

Step 1: Determine Which Workers Need GHS Training

Workers who require hazardous chemical safety training and information under Hazcom also must receive it under GHS.  This includes not just your own employees but those of any outside contractors or subcontractors that are exposed to chemical hazards while working at your facility.

Step 2: Make Sure Person(s) Who Provides GHS Training Is Qualified

GHS training must be delivered by a qualified trainer, i.e., one knowledgeable about:

Step 3: Provide GHS Training at Required Times

  • All workers exposed to hazardous chemicals must (in addition to the Hazcom training already provided) get initial GHS training by Dec.1, 2013;
  • Any worker not currently exposed to hazardous chemicals who’s assigned to new jobs that involve exposure to hazardous substances must receive Hazcom training and GHS training before starting the job;
  • Exposed workers must receive new or re-training whenever new chemical hazards for which they haven’t already been trained are introduced to their work areas; and

Step 4: Ensure GHS Training Covers All Required Information

GHS training must address at least the following:

  • How to read GHS labels;
  • How to access and use SDSs; and
  • How workers can protect themselves from physical, health, simple asphyxiation, combustible dust & pyrophoric gas hazards & hazards not otherwise classified

Step 5: Verify Effectiveness of GHS Training

You must verify that training was effective and that workers understood it and know how to apply it to actual work situations. Methods of verification include:

  • Quizzes testing trainees on the materials;
  • Requiring trainees to demonstrate use of the information, e.g., are able to access and read an SDS; and/or
  • Periodic re-training and testing.

Step 6: Create Written Records to Document GHS Training

You also have to keep written records so you can prove that GHS training was actually provided that list:

Retain GHS training records for at least 30 years—same as required for retaining training records under Hazcom.

PHASE 2: Comply with SDS Requirements - Deadline: June 1, 2016 (Steps 7 to 12)

Overview: Under GHS, MSDSs will become SDSs—Safety Data Sheets. More significantly, SDSs will have a different format and list different information from MSDSs.

Step 7: Determine Which Hazardous Chemicals at Your Workplace Require an MSDS/SDS

Under GHS, hazardous chemical manufacturers must re-classify their products and prepare an SDS for any classified as hazardous under the new classification criteria by June 1, 2015. Employers must keep an up-to-date SDS for each hazardous chemical. Chances are that any product currently classified as hazardous (and thus requiring an MSDS) will also be considered hazardous and require an SDS under GHS. But that’s not a sure thing. So once June 1, 2015 rolls around, you’ll need to revisit your current hazardous chemical inventory and ensure it reflects re-classification. (See Step 21 below for more details.)

Step 8: Make Sure Each Hazardous Chemical Has an MSDS/SDS

By June 1, 2016, all hazardous chemicals requiring an MSDS must have an SDS. But from now until that date, you’ll be in compliance as long as each hazardous chemical at your workplace has either an appropriate MSDS or SDS. There are 2 ways to get an MSDS/SDS: Prepare it yourself; or Request it from the manufacturer, importer or distributor who supplied the product to you.

Step 9: Make Sure Each MSDS Meets Hazcom Requirements

Under current Hazcom requirements, the MSDS must be in English (or other language spoken by your employees if they can’t speak English), up-to-date and list required information about the chemical, its hazards and the safety precautions to take while using it. (Click on the link to find out what an MSDS must list)

Step 10: Make Sure Each SDS Meets GHS Requirements

Under GHS, the SDS must be in English (or other language spoken by your employees if they can’t speak English), be up-to-date and list all of the required information—GHS changes both the SDS format and the information it must list. (Click on the link to find out what an SDS must list)

Step 11: Make Sure MSDSs/SDSs Are Readily Available to Workers

You must ensure that there’s an MSDS/SDS readily available during all shifts to all workers, including those of outside contractors or subcontractors who work with hazardous chemicals.

Step 12: Make Sure There’s a System to Monitor MSDS/SDS Compliance

You’ll need a system to ensure that:

  1. Every new shipment of hazardous chemicals introduced into the workplace between now and June 1, 2015 includes either an appropriate MSDS or SDS;
  2. Every new shipment of hazardous chemicals introduced into the workplace after June 1, 2015 includes an appropriate SDS;
  3. From now until June 1, 2015, old MSDSs/SDSs are updated or replaced with updated or new MSDSs/SDSs;
  4. After June 1, 2015, old MSDSs/SDSs are updated or replaced with updated or new SDSs;
  5. You retain MSDSs/SDSs—or at least the key information they contain—for at least 30 years.

PHASE 3: Comply with GHS Label Requirements - Deadline: June 1, 2016 (Steps 13 to 17)

Overview: Containers of hazardous chemicals will still have to have workplace labels listing key safety information about the product. But GHS labels will have a different look and format and list different kinds of information.

Step13: Determine Which Hazardous Chemicals at Your Workplace Need a Label

Any hazardous chemical that currently requires a workplace label will also probably require a label under GHS.

Step 14: Make Sure Each Hazardous Chemical Actually Has a Workplace Label

All current labels must be replaced with new GHS labels by June 1, 2016. But from now until then, you’ll be in compliance as long as each hazardous chemical at your workplace has either an “old school” or newfangled GHS labels. There are 2 ways to get one of the new GHS labels: Prepare it yourself; or Get it from the manufacturer, importer or distributor who supplied the product to you.

Step 15: Make Sure Each Workplace Label Meets Either Current or GHS Requirement

From now until June 1, 2016, you can use a label that meets either current or GHS requirements. In each case, the label must be in English (or other language spoken by your employees if they can’t speak English), legible and prominently displayed on the chemical container. The difference is the format and information required. (Click on the link for the details.)

After June 1, 2016, workplace labels must comply with GHS requirements.

Step 16: Make Sure Label Alternatives Meet Label Requirements

The above requirements for labels also apply to alternatives used to provide hazard warning information, e.g., signs, placards and process sheets.

Step 17: Make Sure There’s a System to Monitor Compliance with Label Requirements

You’ll need a system to ensure that:

PHASE 4: Revise Your Written Hazard Communication Program - Deadline: June 1, 2016 (Steps 18 to 21)

Overview: Hazcom requires employers to develop a written Hazard Communication Program (HCP) for their workplace. Although GHS doesn’t change the requirement of having an HCP, you’ll have to revise your current so that it complies with other changes to Hazcom made by GHS.

Step 18: Revise the Hazardous Chemical Safety Training & Information Section of Your HCP by Dec. 1, 2013

As before, you must provide workers “effective information and training” on hazardous chemicals in their work areas [See Step 4 above for what such information and training must cover.]  The HCP must describe the measures you take to comply with those requirements. But GHS will affect what you say about training in your HCP:

Step 19: Revise MSDS Section of Your HCP

You’ll need to go through your HCP and, at a minimum, change all “MSDS” references to “SDS” (and change “Material Safety Data Sheet” to “Safety Data Sheet.”). If the MSDS provisions of your current HCP incorporate any of substantive MSDS requirements, you’ll need to change the language to comply with the SDS requirements, e.g., the specific information an MSDS must list will have to be replaced with the information that an SDS must include.

Step 20: Revise Labels Section of Your HCP

The HCP must list the methods you use to ensure that containers of hazardous chemicals have labels, tags or other markings identifying the chemical and warning about the hazards they pose. But GHS changes what labels will look like and what information they must contain.

You will have to revise the HCP if it cites or summarizes specific parts of the current Hazcom label rules 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:

  • The identity of the hazardous chemical; 
  • Appropriate hazard warnings; and
  • 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.

Step 21: Revise Your Hazardous Chemicals Inventor

As before, you’ll need to attach a hazardous chemical inventory to your HCP. But you will have to go back and re-do your current inventory after the manufacturers and importers of the hazardous chemicals you use re-classify their products. The re-classification deadline is June 1, 2015 (Dec. 1, 2015 is the deadline for manufacturers and importers to prepare a new SDS for the re-classified product), but you’ll have a full year to re-do your inventory so that it reflects re-classification.

You’ll need to get SDSs and GHS labels for all hazardous chemicals from your supplier by June 1, 2015 and Dec. 1, 2015, respectively. You’ll then have until June 1, 2016, to revise your hazardous chemical inventory to ensure it reflects GHS re-classification.

PHASE 5: Modify Other Chemical Safety Measures Affected by GHS - Deadline: June 1, 2016 (Steps 22 to 25)

Overview: In addition to directly changing Hazcom, GHS indirectly affects safety measures required by other OSHA standards. There are 4 steps to take to deal with these ripple effects. Deadline: June 1, 2016.

Step 22: Make Changes to Chemical Warning Signs

There are roughly 2 dozen OSHA standards that require employers to post warning signs for a specific type of hazardous substance. You’re going to have to change the language these warning signs (click on the link for a list) as a result of re-classification and new GHS chemical safety definitions.

Step 23: Make Changes to Chemical-Specific Warning Labels

Those roughly 2 dozen standards that require employers to post warning signs also require chemical-specific warning labels for containers of the substance. GHS doesn’t change labeling requirements but does affect the format and information of chemical-specific labels. So you need to modify hazard-specific labels for those substances. (Click on the link for a list)

Step 24: Make Sure Containers of Welding/Cutting Contaminants Have Proper GHS Labels

Containers of dangerous chemicals used in welding and cutting must have workplace labels meeting Hazcom requirements. In general, GHS labels will have a different look and format and have to list different kinds of information. OSHA has also added new label information requirements specifically for dangerous welding and cutting chemicals. Make sure you know and comply with these requirements.  (Click on link for the details.)

Step 25: Modify Other Chemical Safety Programs Affected by GHS

You’re going to have to review chemical safety measures required by standards other than Hazcom and see if they need tweaking for GHS, e.g., changing references to “MSDS” to “SDS.” But there are at least 3 written chemical safety programs where GHS changes might be more than cosmetic:

  1. Chemical Hygiene Plans for Laboratories (required by the Occupational Exposure to Hazardous Chemicals in Laboratories standard Section 1910.1450(e)) (revised definitions of “health hazard,” “reproductive toxins” and “mutagen”);
  2. Operating Procedures for safe handling of highly hazardous chemicals, e.g., flammable liquids and gases, in operations covered by the OSHA Process Safety Management standard (PSM) (revised flashpoints and definitions of “flammable liquids”  and “flammable gases”); and
  3. Safety and Health Programs for employees in hazardous waste operations and Emergency Response Plans at hazardous waste sites required by the Hazwoper ( Hazardous Waste Operations and Emergency Response standard) (revised flashpoints and definitions of “flammable liquids”  and “flammable gases”).

 

 

 

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