SAFETY LABELING IS CHANGING WITH IMPLEMENTATION OF GHS

The Occupational Safety and Health Administration is moving forward towards aligning OHSA's Hazard Communication Standard (HCS) with GHS, the Globally Harmonized System of Classification and Labeling of Chemicals. On October 25, 2011, it was announced OSHA had submitted the Final Rule to the Office of Management and Budget (OMB) revising the current Hazard Communication Standard, with approval expected soon. Alignment of OSHA's Hazard Communication Standard with GHS will affect five million workplaces in the United States and is expected to prevent many fatalities and injuries, as well as save millions of dollars each year.

Within months OSHA may have new requirements for businesses in the United States, making it important for employers to understand the impact alignment with GHS will have on compliance. The time to prepare for the transition to GHS is now. New elements will be required on GHS compliant labels to help convey needed information about each of the hazard classes and hazard categories using standardized elements, such as symbols, pictograms, signal words and hazard statements. Effective labeling is a key component of workplace safety by relaying important information to anyone who may be exposed to potential chemical hazards. Failure to maintain labeling compliance can result in increased accident/injury rates, costly fines and penalties, and decreased efficiency and production.

For those concerned about the upcoming changes involving GHS, now is the time to prepare. Stay compliant throughout the GHS alignment process with help from Industrial Safety Solutions, a leader in cost effective labeling printers and supplies. “In the current economic landscape, many businesses are seeking to achieve their safety and compliance goals affordably,” noted Joe Lyman, Business Development Manager at Industrial Safety Solutions. “We are dedicated to helping companies reach those goals by providing safety labeling solutions at unbeatable prices along with exceptional value and service.”

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GHS IS ON THE HORIZON

GHS implementation in the United States is on the horizon with OSHA's recent submission of a Final Rule to the Office of Management and Budget (OMB) on October 25, 2011. The Occupational Safety and Health Administration submitted the Final Rule proposing to align the current Hazard Communication Standard with GHS, “The Globally Harmonized System of Classification and Labeling of Chemicals”. OSHA expects the GHS Final Rule to be approved for publication soon.

GHS is the internationally recognized system for classifying chemicals and communicating associated health, physical and environmental hazard information. GHS was developed by the United Nations in a worldwide effort to harmonize chemical classification criteria and hazard communication elements for chemical hazard labeling and safety data sheets. OSHA's Hazard Communication Standard was one of four major systems that were the basis for GHS. The United States participated actively in the development of GHS and also participates in the coordination of GHS implementation and maintenance.

GHS is currently in various stages of implementation in 67 countries around the world. Implementation of GHS aids in the protection of human health and the environment by providing a consistent, internationally comprehensible manner of hazard communication to enhance the safe manufacturer, transport storage, use and disposal of hazardous chemicals. Worldwide implementation is expected to increase worker protection and protection of the environment, as well as reduce costs related to the regulatory burdens associated with chemical manufacturing and international chemical trade.

OSHA has been working towards adoption of GHS for some time. In 2006 OSHA published the Advanced Notice of Proposed Rule-making (ANPRM) where they provided information about GHS, and explained the benefits of GHS adoption and the potential impact GHS would have on the Hazard Communication Standard (HCS). The ANPRM comment period ended in November 2006 followed by the Peer Review of the Economic Analysis, which was completed November 2007.

The Notice of Proposed Rule making (NPRM) was published by OSHA in September 2009, and laid the groundwork for alignment of HCS with GHS. The NPRM Comment Period ended in December 2009. followed by public hearings held March 2010 in Washington DC and Pennsylvania. The Post Hearing Comment Period ended in June 2010. On October 25, 2011, OSHA finally submitted the Final Rule to OMB. It is now pending review, which typically takes one to three months.

Implementation of GHS will bring changes in hazard classification and hazard communication that will affect manufacturers, industries, workers, users and the general public in many ways. Alignment of HCS with GHS will significantly impact manufacturers of chemical products responsible for labeling and safety data sheets (SDS). Employers will also be impacted as new GHS elements are adopted for safety labeling. Alignment of OSHA's Hazard Communication Standard with GHS will lead to changes in current labeling requirements. Labels will need updating to include the GHS harmonized elements including symbols, pictograms, signal words, hazard statements, and more.

As the US moves forward in GHS implementation, it is important for manufacturers, employers, workers, safety professionals and emergency responders to become knowledgeable about GHS and the new classifications and communication elements. Hazard communication labeling is an important part of effective health and safety management programs for every workplace and will require education and training. Compliance failure may result in higher accident and injury rates, costly citation fines for violations, and production losses. Now is a good time to prepare for any upcoming changes that your facility may need to make to remain compliant during the GHS transition period.

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OSHA HAS SUBMITTED FINAL RULE – PREPARE FOR TRANSITION TO GHS

On October 25, 2011, the Occupational Safety and Health Administration (OSHA) submitted their Final Rule to the Office of Management and Budget, revising the Hazard Communication Standard to align with the United Nation's Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Under the OSH Act, the Secretary of Labor sets mandatory occupational safety and health standards to ensure safe, healthy work environments for workers, giving OSHA the legal basis for making the proposed changes to the Hazard Communication Standard. OMB has ninety days for review of the Final Rule, with possible extensions if needed. If OMB approves the Final Rule, publication in the Federal Register will take place and OSHA's current Hazard Communication Standard will be revised to align with GHS.

Use of symbols and pictograms, definitions of hazards, requirements for classification, and labeling of chemicals at different life cycle stages varies among the different countries worldwide. They even vary among agencies within the same country. This inconsistency is great enough that different labels and safety data sheets are often needed for the same product when marketed to different nations or agencies, creating compliance and cost burdens.

The different labels and MSDS also create confusion for workers needing to use hazard information. Symbols and hazard statements on varying labels and MSDS may be unfamiliar to workers, leading to lack of understanding. Container labeling may have so much data that critical information is not recognized quickly and easily. As a result of these situations, and because the international trade in chemicals is extensive, there has been an effort for some time to 'harmonize' requirements and develop a system for use worldwide.

GHS was developed by the United Nations based on four major systems, including OSHA's Hazard Communication Standard. GHS is a effort for worldwide harmonization of chemical classification criteria and hazard communication elements regarding safety labeling and safety data sheets. The United nations adopted “The Globally Harmonized System of Classification and Labeling of Chemicals” (GHS) in 2003, with amendments adopted over a period of several years. When the fourth revised edition of GHS was published in 2011, GHS was ready for worldwide implementation. Many countries are now in various stages of GHS implementation.

OSHA has been working towards adoption of GHS for many years. Adopting GHS will reduce compliance burdens and aid international trade, especially for smaller producers who have not had the resources to meet extensive classification and labeling requirements. GHS will: provide consistency of hazardous chemical definitions and information; address concerns of those affected regarding the need for standardizing the format of MSDS; increase understanding by standardizing pictograms and harmonizing hazard statements; and increase worker safety and health through greater understanding and consistency of hazard information.

Integrating GHS into OSHA's regulatory system will improve employee safety, however, it will require work on the part of employers as they transition over and work to become compliant with the new requirements. Failure to follow OSHA standards can result in increased accident and injury rates, citations for violations with costly fines and potential criminal charges, and losses in production. Employers should plan accordingly and prepare for the changes that will be taking place as OSHA applies GHS elements to hazard communication labeling and safety data sheet requirements.

Now is a good time to prepare for the transition as OSHA's Hazard Communication Standard aligns with GHS. Industrial Safety Solutions, a leader in cost effective compliance labeling printers and supplies, is ready to be your compliance labeling solution during this transition period. SafetyPro printers from ISS, with free shipping, free life-time support, and award-winning FacilityWare, make compliance safety labeling economical, fast, and easy! Contact Industrial Safety Solutions for more information – toll-free 877-762-9280, 6:30am – 6:30pm Monday thru Friday.

GHS – IMPLEMENTATION

Harmonizing the existing systems of chemical classification, labels and safety data sheets being used around the world into a single, globally harmonized system was the idea behind “The Globally Harmonized System of Classification and Labeling of Chemicals” (GHS). The GHS “Plan of Implementation” of the World Summit on Sustainable Development was adopted in September 2002 and encouraged countries worldwide to fully implement GHS by 2008. As experience was gained in implementation, the first edition of GHS adopted in December 2002 was followed by amendments every two years, leading to improvements, revisions, and updates to GHS.

Amendments in December 2004 included revising provisions on classification and labeling, and added new guidance on the preparation of Safety Data Sheets and the use of precautionary statements and pictograms. In December 2006, amendments to GHS included additional new and revised provisions including additional guidance regarding interpretation of the GHS 'building block approach', classification and labeling of explosives, guidance on evaluation of carcinogenic potential of chemicals, and the written communication of hazard and precautionary statements.

In December 2008, amendments were adopted concerning allocation of hazard statements, small package labeling, revision of some classification criteria and addition of a new hazard class and two new sub-categories. This third revised edition of GHS was published in 2009. With amendments adopted in December 2010 and published in 2011, the fourth revised edition of GHS was ready for implementation worldwide. These final amendments concerned new hazard categories, further explanation regarding the precautionary statements, and additional criteria clarification to avoid interpretation differences.

The United Nations monitors GHS implementation around the world. GHS has been implemented for 'Transport of Dangerous Goods', and has been implemented, or is in the process of implementation, in 67 countries around the world. In the United States, the Department of Labor's Occupational Safety and Health Administration (OSHA), is working towards GHS implementation which will affect occupational safety and health standards in the workplace.

OSHA's efforts towards implementation include:

  • Publication of the Advance Notice of Proposed Rulemaking (ANPR) on September 12, 2006
  • Publication of a Proposed Rule-making to align OSHA's Hazard Communication Standard (HCS) with the GHS on September 30, 2009.
  • Creating a publication comparing the provisions of OSHA's Hazard Communication Standard to those of GHS.
  • Publishing a guide to GHS.
  • Submission of OSHA's Final Rule on October 25, 2011 to the Office of Management and Budget (OMB) proposing revisions to the current Hazard Communication Standard to align with GHS.

Implementation of GHS may bring many new requirements once OHSA's Final Rule is approved for Publication. Preparing in advance for upcoming changes will help to make the transition to GHS compliance easier and Industrial Safety Solutions, a leader in cost-effective labeling printers and supplies can help . “In the current economic landscape, many businesses are seeking to achieve their safety and compliance goals affordably,” states Joe Lyman, Business Development Manager at Industrial Safety Solutions. “We are dedicated to helping companies reach those goals by providing safety labeling solutions at unbeatable prices along with exceptional value and service.” Call Industrial Safety Solutions toll-free at 877-762-9280, Monday - Friday, 6:30am to 6:30pm. ISS is ready to be your labeling solution!

GHS MAY BE COMING SOON TO YOUR WORKPLACE – ARE YOU READY?

OSHA's Hazard Communication Standard (HCS) covers over forty million workers with a goal of ensuring chemical safety, requiring that all chemicals produced or imported are properly evaluated for hazards and that hazard information effectively communicated via labeling and safety data sheets. Hundreds of thousands of chemical's are covered under OHSA's Hazard Communication Standard which addresses the safety of chemicals thoughout their entire lifecycle from manufacturer to end user, and then finally at disposal.

Employers have a responsibility to protect workers and take measures to protect those who may be exposed to potential chemical hazards in their facilities which may include:

  • Preparing and maintaining a written Hazard Communication program
  • Maintaining an inventory of chemicals used or stored at the worksite
  • Properly maintaining and updating safety labeling
  • Properly labeling secondary containers
  • Properly managing, updating, and providing access to, Safety Data Sheets
  • Providing training on safe practices for chemical handling and use
  • Ensuring employees comprehend information on labels and Safety Data Sheets

OSHA Aligning Hazcom to GHS

On October 25, 2011, OSHA submitted their final rule proposing to align OSHA's current Hazard Communication Standard (HCS) with GHS, “The Globally Harmonized System of Classification and Labeling of Chemicals”. GHS is an internationally agreed upon system for hazard communication adopted by the United Nations, which has requirements regarding hazard classification, labeling, safety data sheets, training and hazard communication programs. OSHA expects the GHS final rule to be approved for publication soon.

GHS is a voluntary system. However, once a country adopts GHS into their system, changes in regulations would become binding on the affected industries. In the United States, the Department of Transportation (DOT) has already modified their classification and labeling requirements to align with the GHS. With submission of the Final Rule, the Occupational Health and Safety Administration (OSHA) is ready to move forward in adopting and applying GHS elements into the framework of OSHA's Hazard Communication Standard (HCS). This will require aligning HCS with GHS.

GHS Bringing Changes to the Workplace

Hazard classification and hazard communication are the two most significant changes GHS will bring to the Hazard Communication Standard. GHS provides criteria for classification of chemical mixtures and substances. Labeling and safety data sheets are standardized with the specified hazard communication elements. GHS 'harmonized' elements include pictograms, signal words, and hazard statements for each of the hazard classes and categories. Under the proposed HCS changes, Safety Data Sheets will have a specified format using 16 sections.

Revising OSHA's Hazard Communication Standard is expected to affect many facilities. Producers of hazardous chemicals will be affected by the alignment of HCS with GHS as it will involve reclassification of chemicals and new labels and Safety Data Sheets. Alignment with GHS will bring changes to the workplace as employers work to manage the influx of new labels and safety data sheets and deal with new compliance issues. In workplaces where chemicals are used, safety labeling may need to be updated and GHS may need to be integrated into facility hazard communication programs. Workplace training will need to be provided to ensure employees recognize and understand the new GHS symbols, pictograms, hazard statements and other information on the new labels and Safety Data Sheets.

What Can Employers Do to Get Ready for GHS?

As GHS implementation takes place, transition planning will be an important part of every facility. Employers will be required to provide GHS training to their employees and there will be deadlines on compliance. Unfortunately, many employers are only vaguely familiar with GHS. With preparation, the transition to new GHS requirements can be made smoother. Create a transition plan and find vendors who will support your transition to GHS.

Preparation includes:

  • Keeping updated on important GHS implementation dates
  • Understanding the potential impact the change may have on your facility.
  • Completing inventory of all chemicals in your facilities.
  • Inspecting workplace labeling and updating for compliance with GHS.
  • Watching the deadlines for compliance.
  • Reviewing your safety data sheet library for completion and updating as needed.
  • Developing and maintaining an effective Hazard Communication Plan.
  • Educating management and providing GHS training programs for all personnel.
  • Preparing early so it will be easier to have a successful transition to GHS.

Impact of GHS on Workplace Costs

Over 5 million workplaces and over 40 million workers will be affected by the proposed alignment of HCS with GHS. Costs will be associated with reclassifying all chemicals in accordance with the GHS criteria, revising material safety data sheets and labels in the new content and format, and training workers on the new modified HCS Standard, the new MSDS format, and the new warning symbols, though they are are expected to be 'one-time transition costs' during the phase-in period. OSHA expects the annual compliance costs associated with the proposed changes to the HCS to be the same or lower than before the changes.

OSHA has estimated that 43 fatalities and 585 injuries and illnesses will be prevented annually due to revising the HCS to align with GHS. Annual monetary benefits associated with reduced safety and health risks, reduced costs, and improved productivity, are estimated by OSHA to provide a net annual savings of $754 million a year.

Benefits of Alignment with GHS

Participating in worldwide implementation of GHS helps to improve the quality and consistency of classification and labeling of chemicals which allows information to be accessed more efficiently and will enhance worker understanding of the appropriate use and handling of chemicals. Increasing the quality of information provided to workers, employers and other users of chemicals, as well as improving the consistency in which that information is provided, are main benefits of adopting GHS. Implementing GHS in a consistent manner helps to enhance public and environmental protection, and enhances worker protection, resulting in fewer fatalities and injuries, saving millions each year.

Alignment with GHS will also facilitate international trade. Creating different labels and Safety Data Sheets for different countries is burdensome for chemical manufacturers and international trade companies. Adopting GHS reduces this compliance burden, requires less duplication of testing and evaluation, provides assistance in sound chemical management, and reduces the costs involved in providing hazard information.

Additional benefits of implementation of GHS include reduced enforcement costs, lower health care costs, improved employer/employee relationships, improved corporate images for companies, and increased efficiency and production.

Be Prepared

With many key changes on the horizon, now is the time to prepare. OHSA's Hazard Communication Standard alignment with GHS may bring new compliance requirements. Now is a good time to prepare for the changes needed to remain in compliance during the GHS transition period. Failure to remain compliant can result in higher accident and injury rates leading to costly citation fines for violations in addition to reductions in efficiency and production losses.

To help make your transition to GHS easier, contact Industrial Safety Solutions, a leader in cost effective industrial labeling printers and supplies. ISS makes your job easier by providing quality products, knowledgeable staff and exceptional service at unbeatable prices. Free shipping and life-time tech support add to the value! For great package deals and incredible savings, call Industrial Safety Solutions today, toll-free at 877-762-9280. ISS is ready to be your compliance labeling solution!