How Does GHS Affect Me?

This article is the second in a three part series on hazard standards and labeling. Read the first article on GHS here.

Now that we have defined GHS (Globally Harmonized System) , its purpose and the changes to the hazard communication system,  let’s discuss how it will affect you. The requirements of the global harmonization system will affect everyone from the manufacturer to the end user. In this post we will discuss the regulatory timeline and the basic requirements. If you need additional information we encourage you to access OSHA’s webpage for full text of the regulation and letters of interpretation.

New Labeling and SDS Regulatory Timeline

The OSHA standard has determined the following specific dates of compliance for training, manufacturer labeling, and workplace labeling and hazard communication program updates:

  • All chemical manufacturers, importers, distributors, and employers must be using GHS compliant labels and data sheets by June 1, 2015. Further details of this information can be found at 29CFR1910.1200 (J) 1-3.
  • Chemical Distributors can no longer ship non-GHS compliant labeled containers after December 1, 2015.
  • Hazard Communication and workplace labeling are to be updated by June 1, 2016.

Review the visual representation of the GHS Implementation Timeline.

Workplace Changes

By December 1, 2013, all of your employees were trained on the new label elements and the safety data sheet format.

If you have a hazard communication program and workplace labeling in place at your company, you will have to update them to be in line with the GHS standard by June 1, 2016. Included in this requirement is the need to train your employees on any newly identified physical or health hazards.

Hazard Communications per GHS

Below are the details from the OSHA regulation 29CFR1910.1200 (h)1-3, the requirements for a globally harmonized hazard communication program.

  • Provide employees with information on the chemicals in their work area at initial assignment or when new chemicals are introduced
    • Training can cover hazard categories or specific chemicals
  • Employees should be informed of:
    • Operations in their work area where hazardous chemicals are present
    • Location of Hazard Communication program
    • List of hazardous chemicals
    • SDS for hazardous chemicals
  • Employees training needs to include:
    • How to detect the presence or release of hazardous chemicals in their work area
    • The physical and health hazards of the chemicals in the work area
    • Measures employees can take to protect themselves from the hazard
      • Work practices
      • Emergency procedures
      • Personal Protective Equipment
    • Details of Hazard Communication program designed by employer including:
      • Explanation of labels on raw materials and workplace labeling
      • Safety Data Sheet
        • Order of information
        • How employees can find and use the hazard information contained in the SDS

Workplace Labeling

Some of the requirements of the old standard are carried through to the new standard. The need to make your employees aware of the chemical hazards in the work place, defaced/damaged labels have to be replaced with a workplace label ASAP and the labeling exemption for materials in containers intended for immediate use are all in still in place. We have been using HMIS here for years but the new standard, with its additionally required information, makes the old program inadequate. Words, pictures and symbols can be used to convey the information that needs to be included in the workplace labels. The pieces of information required are:

  • Product identifier
  • Signal Word
  • Hazard Statement(s)
  • Pictograms(s)
  • Precautionary statement(s)
  • Name, address, and phone number of chemical manufacturer, importer or other responsible party

If labeling each individual container seems like a huge undertaking for your site, you will be happy to know there are options available. Providing you are able to include all of the above listed information OSHA allows the use of one of the following:

  • Signs
  • Placards
  • Process sheets
  • Batch tickets
  • Operating procedures
  • Other written materials

Fortunately, there are some expanded HMIS signs and labels already on the market with all of the required information, so it’s a matter of finding one that works for your company.

Want to learn more about the GHS Safety Standards, read this related article:

Hazzard Communication: What is GHS