Following Up On GHS — What’s Next?
The worker training deadline for GHS has passed, but more changes lie ahead.
World peace seems less likely with each passing day, but global harmony is coming.
The Globally Harmonized System (GHS) for labeling, listing and classifying chemical hazards was developed by the United Nations with input from many countries, including the U.S.
Although this process began in 1992, it has only recently begun to be implemented.
For the U.S., in March 2012, the Occupational Safety and Health Administration (OSHA) published notice of revision of its Hazard Communication Standard to conform to GHS.
GHS covers physical safety, health and environmental hazards.
Prior to international acceptance of GHS, there was a myriad of standards in countries across the globe.
This made it difficult for manufacturers and shippers to carry on chemical sales in other countries where a product might need to be labeled differently in every country.
In addition, to the goal of eliminating this confusion, GHS hopes to provide a basic framework for many countries that had no regulation for labeling, packaging and shipping of chemical products.
It is hoped this will provide greater safety and protection for citizens of those countries.
Another goal of GHS is to reduce product testing, especially on animals.
Thus, if a specific mixture of ingredients has not been tested, rather than requiring the new combination to be tested, the classifications of the individual ingredients will be considered even if the mixture is diluted with an ingredient known to be less hazardous, such as water.
The information will target numerous groups including manufacturers, distributors, transportation companies, employers and employees who use chemical products, emergency responders, consumers and the public.
Who Will Be Affected?
The first group affected by the implementation of GHS was employers.
No later than December 1, 2013, all employees should have received training to understand new product labels and Safety Data Sheets (SDS, formerly known as MSDS).
The training requirement applied to both full-time and part-time employees if they use or work in a facility where chemicals are used.
OSHA provided information on what the training should include as well as sample labels and SDS to use in training.
This training should have included an explanation of the standardized 16 sections that will be included on each SDS, which information is contained in each section and how to use that information in the course of their work activities.
An employee who understands the SDS will know where to find information on:
- Specific hazards such as oral toxicity or skin irritant (Section 2)
- How products should be properly stored (Section 7)
- Hazardous ingredients (Section 3)
- The physical and chemical properties (Section 9)
- Specific exposure limits (Section 8)
- Ways to limit exposure (engineering controls) (Section 8)
- What personal protective equipment should be used (Section 8)
- How to respond to an accidental spill (Section 6)
- Proper disposal of waste material (Section 13)
- Where to locate needed information in the event of a medical emergency (Section 1).
Changes to labels and safety data sheets are not required to be in place until June 1, 2015.
However, some chemical manufacturers and distributors are already beginning to phase-in the new format.
So, you may be seeing this long before June 1, 2015.
What Will Change?
Both labels and SDS will include pictograms.
We are all familiar with the silhouette of a cigarette with a red circle and line through that indicates “No Smoking” and the skull and crossbones symbol that indicates a poison.
For many years the U.S. Department of Transportation has required pictogram symbols on shipments of certain hazardous materials.
Expect to see more very visible pictograms on product labels as well as SDS.
Pictograms will indicate hazards such as peroxide or other ingredients that may react, oxidizers, ingredients that are flammable, corrosive, skin irritants, as well as other acute or long-term health hazards.
Many products you use are likely to display more warnings and hazard symbols that in the past.
Signal words will be used to indicate the relative severity of a threat.
Danger means the hazard is more severe, while Warning will be used for less severe hazards.
There will also be statements with a more specific description of the potential hazard.
Here is an example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.”
Further statements will recommend preventive measures that should be taken as well as steps to be taken should first aid become necessary.
Although the content of the bottles and jugs you carry may not have changed, this labeling could attract the attention of your prospects, clients and the public at large.
Advance consideration of how they might react will be beneficial.
For example, you may wish to mix products at your shop at the beginning of each day’s activities.
One issue that is not addressed by GHS is the matter of trade secrets.
The listing of specific ingredients and the percentage or amount of each ingredient will be regulated by each countries own law.
So, U.S. law will continue to dictate how trade secret ingredients are handled on products manufactured in this country.
Safety Data Sheets will be updated regularly to ensure that workers and emergency personnel always have up-to-date information available.
As with the former system, the information must be readily available to the technician.
Previously, manufacturers were allowed some discretion in stating the seriousness of health or toxicological issues.
Now, toxicological data will be based on one standard manner of testing.
You will see the notation LD50; this is the lethal dose required to kill 50 percent of a species it is tested against.
Description of toxicological information will be more accurate and consistent.
It must be specific, concise, complete and easily comprehended even by those with limited ability of the language.
Thus all workers should be aware of hazards that face them.
The manufacture, distribution and exporting of chemical products is a multi-billion dollar business for the United States economy.
Acceptance of this international standard should make it easier to compete.
The clearer and easier to understand safety information should provide a safer work environment.
This will benefit both employers and employees.
Costs resulting from accidental injuries and illness will be reduced.
Greater awareness of potential dangers should keep workers safer.
Multiple versions of what is essentially the same product (maybe one with citrus scent and another with floral fragrance) will only require one SDS.
This will reduce paperwork and time in keeping the information up-to-date.
On a national and international level, consistency should make enforcement easier; reduce costs associated with duplication of efforts from various countries and enforcement agencies; and lower healthcare costs due to fewer injuries, accidents and long-term health issues.
Countries with little or no regulation in place will be able to implement safety and environmental regulations faster, easier and at lower cost.
The second phase of the Globally Harmonized System for classifications of chemical and environmental hazards is coming.
Now is the time to be prepared.
Scott Warrington has more than 40 years of experience in the carpet cleaning industry and related fields. He serves as the technical support specialist for Bridgepoint Systems and Interlink Supply. He can be contacted at ScottW@Bridgepoint.com.
GHS Compliance Dates
These are the rolling effective dates for the new standard:
June 1, 2015: Manufacturers are required to comply with all the provisions of the new standard.
December 1, 2015: Distributors shall not market or ship chemicals unless they have the GHS label.
June 1, 2016: Workplace labeling is to be updated so that it conforms to SDS, and additional training is to be provided on the program and labeling elements.