You may have heard that OSHA is revising its Hazard Communication Standard (HCS) to align with GHS.
You may know that a final rule revising the HCS will mean big changes for U.S. companies that use hazardous chemicals, with the most noticeable changes being to safety labels and material safety data sheets or MSDSs.
You may even be doing your due diligence to prepare for a final ruling expected in early 2012 — however, did you know many chemical manufacturers in the U.S. and around the world have already started using GHS styled MSDSs?
It’s true, and every U.S. employer that uses chemicals and maintains MSDSs under Right-to-Know regulations should be on the lookout for these new MSDSs.
Ask yourself these questions, “Do the people on the front lines of my organization know to be on the lookout for these new MSDSs, especially for those chemicals we receive on a regular basis? Does my procurement office know to check incoming MSDSs against the current MSDS library in case of updates? Does that dock worker who accepts 99% of my chemical shipments know how to identify a GHS styled MSDSs?"
If you answered no to any of these questions, you have a little work to do.
Of course, even the current HCS requires companies to maintain an up-to-date MSDS library; however, with the changes to MSDS formatting coming down the pike thanks to GHS, companies can expect their entire MSDS library to be updated in a relatively short time frame.
So what should your people be looking for? Under GHS MSDSs are called safety data sheets (SDSs). The GHS SDS format has a standardized 16 section layout, and includes GHS pictograms. Pictograms are safety symbols that convey an illustrated warning related to type of hazard a given chemical poses.
The inclusion of pictograms does not ensure that the safety data sheet is a GHS styled SDS; however, it is a good place to start.
Maintaining compliance during OSHA’s transition to GHS is going to be the key to maintaining a safe workplace for your employees, and it’s a job that starts today. Don’t wait until OSHA issues its final rule on GHS to at least get familiar with the new safety data sheets and make sure those people who are on your front lines know what to look for and can pull those SDSs for inclusion in your SDS library.
It’s also a good time to take a look at your MSDS management and workplace labeling systems and consider whether electronic MSDS management can help make the transition to GHS a smooth one. To learn more about GHS and GHS styled SDSs, visit the GHS Answer Center.