Complying with OSHA’s New Globally Harmonized System

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oshaAs of December 1, 2013 the employer compliance requirement for the Globally Harmonized System (GHS) will go into effect. If your employees handle chemicals you are affected by this law and must comply with the training requirements mandated by December 1st. The program will cover businesses that previously were unaffected. Any business using chemicals must begin complying with OSHA’s Globally Harmonized System by that date.

The Globally Harmonized System is a universal warning program for chemicals used in the workplace. Development began in 1992 at the United Nations Conference. This program supercedes previous OSHA standards. The goal is to warn employees of the risks to themselves and teach them proper handling of these chemical to lessen the environmental impact.

OSHA has always required employers to warn employees of the risk to their personal safety when handling dangerous materials. Employers must equip employees with adequate protection and train them in how to protect themselves when performing hazardous tasks. The new GHS requires more detail in the information provided employees for handling chemicals. It also mandates a structure for training. Basically, the program has three parts:

  • Hazard Classification
  • Labels
  • Safety Data Sheets

Hazard Classification (Signal Words)- GHS has two classifications of ‘warning’ and ‘danger.’ Warning means there are serious health risks. Danger is applied to life threatening chemicals. For compound chemicals, the signal word is based on the most toxin chemical. All chemicals must carry a signal word.

Labels

Chemical manufacturers must supply employers (and all end users of their products) with labels that include a signal word (warning or danger), pictogram and hazard statement for their products. Employers must make certain these labels are applied and that employees understand how to read the labels and use the information. If you have not requested your labels from the manufacturer, you can probably download it from their website. (Or, use the label art on the OSHA site.)

Safety Data Sheets

These data sheets must cover 16 points of information and be distributed to all employees. Employers must train their employees in each of the 16 points. This information can be obtained from the chemical manufacturer. Most of it will be on the product label, however, if the information is not supplied or incomplete, employers are still responsible for training in all 16 points. Your Safety Data Sheets must include:

  1. Identification including the name of manufacturer, the chemical and batch number
  2. Hazard(s) identification (specific risks to employee)
  3. Composition listing all ingredients
  4. First-Aid measures in the event of exposure
  5. Fire-fighting measures in the event of a fire
  6. Accidental release measures
  7. Safe handling and storage
  8. Exposure controls including personal protection
  9. Physical and chemical properties
  10. Stability and reactivity
  11. Toxicological information
  12. Ecological information
  13. Disposal considerations
  14. Transport information
  15. Regulatory information
  16. Other information, including date of SDS preparation or last revision

Keep your data sheets in a binder in the break room. Also, hand them out to all employees and new hires. Have your employees sign a receipt that they have gotten the handouts.

For more about the 16 points of information required on the Safety Date Sheets, visit: https://www.osha.gov/Publications/OSHA3514.html

Special Instructions

Pictograms

There are nine pictograms and employees must be taught what they mean. They aren’t very intuitive, so your employees will have trouble remembering them. The best way to comply with this requirement is to include the descriptive word, along with the pictogram. If you have a bi-lingual workforce, you will need to display the pictograms in as many languages as required by your workforce. Employers cannot use the excuse that the employees couldn’t remember the pictograms. You must communicate the information about safety hazard in a way that all employees will understand. The nine pictograms are:

ghs-symbols

Health Hazard — carcinogen, mutagenicy, respiratory sensitivity, reproductive toxin, target organ toxin, aspiration, toxin
Flame — flammable, pyrophorics, self-heating, emits flammable gas, self-reacting, organic peroxides
Exclamation Point — irritants to skin, eyes and lung, hazard to ozone
Gas Cylinder — gas under pressure
Corrosion — Burns skin and eyes, corrosive to metals
Exploding Bomb — Explosives, self-reacting, organic peroxides
Flame over Circle — oxidizer
Environment — aquatic toxicity
Skull and Crossbones — acute toxicity

You’ll find the artwork for the pictogram at https://www.osha.gov/dsg/hazcom/pictograms/. You can download the art files and print them out on labels. When applying the Pictogram labels, be careful not to cover any of the information on the product label about its use, proper storage or disposal.

Red Borders

The new law insists that pictograms be shown with red borders. If you print out the pictograms for labels, training or to post as a reminder to your employees, make sure you do it in two colors, red and black.

Updates

Manufacturers have six months to update their customers with the newest information safety information about their products. Employers are responsible for making their employees aware of this information. Document your safety records each time you update the Safety Data Sheets with new information and distribute them to your employees.

Training your Employees

There are a number of affordable training services that can help you meet the December 1 deadline. Hiring one of these service providers doesn’t automatically meet the requirements for employer compliance. If information is left out about a chemical, or new hires do not receive full instruction, the employer is responsible.

Training employees internally demonstrates a commitment to employee safety, and it gives you an opportunity to review your storage and handling procedures. It’s also a chance to talk with employees about their concerns and come up with practical solutions. Here’s the steps for preparing for your training session:

  1. Review all of the chemicals stored on your premises and collect the Safety Data Sheet information from the manufacturer. Check their website or give your sales rep a call.
  2. In your session, cover all 16 points of information on the Safety Data Sheets guidelines. Go over the proper use of all safety equipment, emergency procedures for accidents, first aid to injured employees, storage procedures and disposal procedures.
  3. Review the pictogram for each chemical and what it means. Hand out a reference sheet and post the pictograms wherever chemicals are stored.
  4. After the session is over, document which employees attended by having them sign out. Before you close, make sure you ask for questions and address all concerns.

For new hires, assign trainers to cover the 16-point information Safety Data Sheet and the pictograms. Document by collecting a signed receipt for the handouts you give to each newly hired employee. A simple state like this one will do:

“I acknowledge receipt of the Safety Data Sheets for (list the chemicals). I have been trained in safe handling, storage and proper disposal of these chemicals. I agree to review this information. I understand that not using my safety equipment and follow safety procedures is grounds for termination.”

In your training, be sure to cover storage and emergency procedures for all chemicals, not just the ones an employee uses for his job. If you use a training service, make sure they include all four of these steps in their program.

OSHA estimates that these new GHS standards will save 43 lives every year and 585 serious injuries and illness. They assign a monetary value of $250 million for worker injury and $475.2 in lost productivity. The real value to employers is workers who are more productive and confident in their job when properly informed, equipped and trained for the hazards of their job.

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