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Countdown: 30 Days to Meet OSHA’s GHS Training Deadline
What you need to know to be compliant

By Roy Maurer  11/1/2013
 
 

Employers storing, using or handling chemicals must provide workers with compliant Hazard Communication Global Harmonized System (GHS) training before Dec. 1, 2013.

The Occupational Safety and Health Administration’s (OSHA) revised hazard communication standard is being aligned with the GHS for global consistency. The compliance deadlines are being rolled out in phases, with the first phase of the new guidelines requiring businesses to train their employees on the changes before Dec. 1.

Even businesses using consumer-grade chemicals such as paints and cleaning supplies must provide workers with OSHA-compliant training under the new rules.

OSHA has mandated that all affected workers must be trained to read and understand the new safety data sheets and chemical labels.

“Complying with the new GHS elements is not difficult,” said Rick Johnson, vice president of development for CLMI Safety Training, one of the leading sources for safety training videos and programs. “Since many companies have not provided any training since their initial training on hazard communication, now is an excellent time to refresh workers on the safe use of chemicals in the workplace,” said Johnson, a certified safety professional. “The most important thing for workers to do is take a moment to read the label of the product that they are about to use and confirm that the hazards of the product are in control,” he said.

Here are the five most important takeaways you need to know:

Why the Changes and Why Now?

Hazard communication has been one of the most frequently cited standards by OSHA for years. In fiscal year 2012, it was the most frequently cited standard for general industry.

In March 2012, OSHA revised its hazard communication standard to align it with the United Nations’ GHS.

The agency said that on an annual basis the changes will result in the prevention of 43 fatalities and 585 injuries and illnesses, 203 lost-workday injuries and illnesses, and 64 chronic illnesses. OSHA estimates that overall, companies will save an estimated $250 million a year due to the reduction in occupational injuries and illnesses. The total cost for implementing and maintaining the revised standard is estimated at $200 million a year.

Why does this training have to be completed this year if other parts of the standard don’t kick in until 2015? “There are already some countries that have adopted GHS, including those in the European Union, the United Kingdom, and China, so we’re already seeing the new labels and new data sheets being used,” said Marie Athey, an environmental health and safety expert and director of EHS product management for 360training.com, a provider of online health and safety training.

Employees need to know how to use the new documentation; however, employers are not required to maintain two sets of labels and safety data sheets for compliance purposes. Until the new standard takes effect in 2015, labels and safety data sheets adhering to either the current standards or the new standards will be considered acceptable.

When Are the Deadlines?

By Dec. 1, 2013, employers are expected to have trained their workers on the new label elements and safety data sheet formats required under the standard. This means all U.S. workers who come into contact with any chemicals in the workplace will have to be trained to understand how to interpret hazards communicated through brand new labels and pictograms, and standardized safety data sheets.

The training deadline is the first of several under the revised standard over the next three years. The next deadlines are:

June 1, 2015: Chemical manufacturers, importers, distributors and employers must comply with all other requirements of the revised standard.

Dec. 1, 2015: Distributors may not ship containers unless they contain approved labels.

June 1, 2016: Employers must update workplace labeling and their hazard communication programs as necessary, including additional employee training for newly identified chemical hazards.

What Are the New Labeling Requirements?

OSHA expects employers to train their workers on understanding the new label elements.

The new labeling requirements describe the uniform way to convey the hazards and controls associated with every chemical product, said Johnson. This is going to be a lot of work for manufacturers of chemical products, he said. “For the user of these products, the advantage is that the language and the pictograms will be more uniform and easier to understand. More information will be on the label and this makes it easier to work with the product safely.”

Training on the standard should go over the effective use of labels, for example, to locate needed first aid information, and explain how label elements may overlap, such as multiple hazards identified via pictograms.

The six elements in more detail:

The product identifier, for example, the chemical name, code number or batch number. This is given by the manufacturer, importer or distributor.  It is important to note that the product identifier must be the same on both the label and in Section 1 of the safety data sheet.

Signal words. One of two signal words will be used to indicate the relative level of hazard severity: danger or warning. Within a specific hazard class, danger is used for the more severe hazards and warning is used for the less severe hazards, said Athey. Only one word will be used on the label, regardless of how many hazards the chemical may have, and it must always be the highest-level severity word, she said.  

Pictograms. There are nine OSHA designated pictograms, of which eight are mandatory:

  • Health hazard.
  • Flame.
  • Exclamation mark, representing skin and eye irritant.
  • Gas cylinder, representing gases under pressure.
  • Corrosion.
  • Exploding bomb.
  • Flame over circle, representing oxidizers.
  • Skull and crossbones, representing acute toxicity, possibly fatal.
  • Environment, representing aquatic toxicity (nonmandatory).

Hazard statement, describing the nature of the hazard of a chemical, including the degree of hazard, if appropriate. An example would be: Causes damage to kidneys through prolonged exposure to skin.

Precautionary statement, describing recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage and handling.

Labels must be legible, in English, and prominently displayed. Other languages may be displayed in addition to English. Chemical manufacturers, importers and distributors who become newly aware of any significant information regarding the hazards of a chemical must revise the label within six months, OSHA said.

How Are MSDSs Changing?

Another of the revised hazard communication standard’s significant changes is the replacement of the current material safety data sheet (MSDS) reporting format with standardized safety data sheets (SDSs). These will cover everything from potential hazards of the chemicals, first aid measures and how to control exposure, transport and dispose of the material.

“One very big way they are not changing is their fundamental nature. Whether they’re called MSDSs or SDSs, their purpose remains the same, which is to provide critical information about the proper and safe handling, storage, use and disposal of chemicals to everyone in the lifecycle of said chemicals,” remarked Glenn D. Trout, the president of MSDSonline, a provider of on-demand compliance solutions for tracking and managing hazardous chemicals and GHS compliance. Information found on the MSDS or SDS is particularly helpful in training employees and responding to chemical emergencies, he said.

Another big way MSDSs are changing is that they are getting a standardized format. Trout explained that safety data sheets currently come in many formats, including 8-section, 12-section, and 16-section documents. The GHS format that OSHA adopted contains 16 sections and provides a description of the data used to identify hazards. “The first 8 sections is for information most needed in an emergency or to prevent one, while sections 9-16 contain more technical and perhaps less urgent information,” Trout said.

The 16 sections are:

  • Identification of supplier.
  • Hazard(s) identification.
  • Composition/information on ingredients. This includes mixtures and trade secret claims.
  • First-aid measures. “Probably the first thing I’d train my employees on,” Athey said.
  • Fire-fighting measures.
  • Accidental release measures. “This is something that will happen in the workplace, so be prepared,” she said.
  • Handling and storage. This section includes incompatibilities, such as ammonia and bleach, which creates a toxic gas when mixed together.
  • Exposure controls/personal protection. Permissible exposure limits will be listed here.
  • Physical and chemical properties.
  • Stability and reactivity. Another important section when it comes to storage, said Athey.
  • Toxicological information.
  • Ecological information.
  • Disposal considerations.
  • Transport information.
  • Regulatory information.
  • Other information, including date of preparation or last revision.

“You will have to train your employees to understand that the information on the label is related to the SDS. For example, the precautionary statements should be the same on both,” said Athey.

OSHA estimates that approximately 1.4 million MSDSs in the U.S. need to be updated, Trout said. Then things should get a lot easier for employees regarding the use of safety data sheets, he said. “First, there will be a consistent format regardless of manufacturer or product. Second, hazard information on the safety data sheet should be more consistent across industries and products. Third, information found on the labels of shipped chemicals will match information found in section 2 of the safety data sheet. And fourth, just the activity of reclassifying chemicals and updating the safety data sheets will allow companies to incorporate best practices and any new information that may be available since the safety data sheet was last authored.”

Trout advised that employers start preparing for the changes today. “Make sure you have an up-to-date MSDS library, because as the new documents come in, you will need to compare them to the old ones to see if there are any new hazards that have been identified. Also, employers should expect their entire safety data sheet library to turn over in the next few years. That could mean a lot of paperwork updating dozens, hundreds or even thousands of safety data sheets across facility locations. Finally, employers should stay patient. The changes are happening, but downstream users have to wait for the manufacturers and distributors to make the changes before they can update their own libraries. Employers may want to help prime the marketplace by letting their chemical suppliers know they are awaiting the updated documents and sooner is better than later.”

What Are the Training Requirements?

The revision of the OSHA hazard communication standard to align with the GHS will change the way material safety data sheets have been used by many since the 1980s. As a result, it’s important that practitioners understand the various physical, health and environmental hazard classifications and the underlying concepts for assigning those classifications, said Mary Ann Latko, managing director of the American Industrial Hygiene Association’s Registry Programs.

“If you are a health and safety practitioner who reviews SDS and labels for training or risk management purposes, you should ask yourself: are you ready? Can you train others? Do you have a professional with expertise in this area whom you can use to meet the Dec. 1 deadline? If not, there is still time to gain the training you and your employees need—but not much.”

OSHA has updated its hazard communication page to help employers make the transition to being compliant with the revised standard. Helpful publications include a fact sheet that covers the standard’s training requirements and a brief that the agency created explaining labels and their elements, what pictograms are and how to use them.

“Just throwing these OSHA resources at your employees in no way constitutes training,” said Athey. “You’ve got to present information in the manner and language that your workers can understand, taking into account those employees that don’t speak English, have limited vocabulary or are illiterate,” said Athey. “Make sure that you’re overcoming training limitations or it doesn’t make any sense to do the training at all and won’t satisfy the training requirements.”

Successfully Train Your Workforce

Rick Pollock, the founder and president of CLMI Safety Training, provided the following tips to effectively train your affected workforce on GHS.

  • Choose the most clearly presented, complete, accurate and interesting training materials you can find. “You have many choices, so choose what’s best for your needs,” Pollock said.
  • Make sure that the training about the labeling criteria is separated from that on safety data sheets. “When a person is introduced to the GHS labeling system it takes a while to comprehend and differentiate each pictogram and then understand the variety of detailed warning information that will accompany each one. It’s like learning a new language; since the pictograms and many of the hazard categories and terms will be new, being able to quickly identify and explain them with accuracy will take practice,” he said.
  • Focus on helping individual workers learn the specific pictograms and hazard warning statements that apply to them, the chemicals they use and the work they do.
  • To help workers learn the new SDS categories or sections provide a learning exercise that requires them go through a sample SDS to find specific information. Have them do this a few times, varying the information they need to find.
  • Be sure to have follow-up discussion and reinforcement activities built into the training plan. Pollock said you can do this by using posters, booklets, hand cards, short tool-box talks, or a series of reminders in the company newsletter or employee website.

Roy Maurer is an online editor/manager for SHRM.

Follow him on Twitter @SHRMRoy.

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