Date First Published on SafetySmart Compliance: June 5th, 2012
One of the key aspects of the OSHA Final GHS Rule that you need to know about are the changes to workplace label requirements. Here’s a quick overview of the changes and when you must comply with them.
Click here for a step-by-step gameplan for complying with label requirements—both current and under GHS
HOW GHS CHANGES LABEL REQUIREMENTS
Under GHS, workplace labels will continue to play a crucial role in communicating information about hazardous chemicals to workers.
Who Creates Workplace Labels
As under current rules, the company that manufactures or imports the chemical must create the workplace label and ensure it’s properly attached to each container of the product (although employers may also prepare their own labels if they want to).
The employer that uses the hazardous chemical downstream must ensure that each container has an appropriate, legible label that remains firmly attached and that all exposed employees are trained how to read the label.
Click on the link to find out more about GHS training requirements.
The Difference between Hazcom & GHS Labels—Appearance
One of the biggest differences between Hazcom and GHS labels is what the labels look like. Here’s a side by side comparison:
Visually, there are 3 things about the GHS label that jump out, even to the untrained eyeball:
- It lists more information than the current label;
- It includes graphic symbols; and
- It contains a third color—red.
The Difference between Hazcom & GHS Labels—Information Listed
And that brings us to the next and most important difference between the labels: the information they must.
The current Hazcom label must list:
- Identity of hazardous chemical, i.e., IUPAC chemical or common name as listed on the MSDS;
- Appropriate hazard warnings or words, pictures, symbols or combination, providing: i. at least general information about chemical’s hazards; and, ii.that, in conjunction with the other information immediately available to employees under the Hazcom program, furnish them specific information about the chemical’s physical or health hazards (click on the link to find out how GHS affects the GHS program); and
- The name and address of the chemical’s manufacturer, importer or other responsible party.
The GHS label must list:
- Product identifier, i.e., hazardous chemical’s name or number;
- Signal word, i.e., “danger” for more severe hazards, “warning” for less severe ones;
- Hazard statement(s), i.e., statements assigned to a hazard class and category describing the nature of the hazard(s) of a chemical and, where appropriate, the degree of hazard;
- Pictogram(s) in the shape of a square set at a point that include a black hazard symbol on a white background with a red frame wide enough to be clearly visible (Click on the links to find out more about GHS pictograms and hazard symbols).
- Precautionary statement(s), i.e., phrases describing recommended measures to take to minimize or prevent adverse effects of exposure, improper storage or handling; and
- Name, address & phone number of manufacturer, importer or other responsible party.
When You Must Be in Compliance with GHS Label Requirements
The transition to full use of the new GHS label will be carried out in stages:
- Dec. 1, 2013: You must have trained employees to use new GHS labels (and new Safety Data Sheet (SDS), which replaces the current MSDS (click on the link to get more information about GHS training requirements);
- June 1, 2015: Manufacturers and importers must reclassify their chemicals and prepare an appropriate SDSs; (Click here to find out more about making the transition from MSDS to SDS)
- Dec.1,2015: Manufacturers and importers must prepare new GHS labels; and
- June 1, 2016: Employers must ensure each hazardous chemical has GHS-compliant label and SDS.
For More Help Complying with GHS Label Requirement
Click here for a step-by-step gameplan for complying with current and new GHS label requirements
Click here for a Hazcom training checklist you can use to comply with training requirements
Click here for a more detailed comparison of the information required in current and GHS labels