Chemical Safety and OSHA GHS Compliance in 2013: a Call to Action and a GHS Checklist

The start of a new year can be a time of powerful transformation. It can feel like a clean slate and a chance to be a little (or a lot) better this year than we were last year.In 2013, this is especially true for safety professionals in the areas of chemical safety and GHS compliance. For safety professionals, this must be a year of action.

To help you keep your GHS responsibilities straight – download our GHS / HCS Compliance Checklist

GHS Deadline

It has been almost a year since OSHA formally solidified its alignment with the Globally Harmonized System (GHS) in the Federal Register via a revision of the Hazard Communication Standard (HCS). Known informally as HazCom 2012, the revised HCS went into effect in May and we are now less than a year away from its first GHS related compliance deadline, December 1, 2013.

By December 1, employers with employees exposed to hazardous chemicals must have trained those employees on GHS formatted chemical label elements and GHS formatted safety data sheets. For those safety professionals uninitiated with GHS, or with many employees to train, this deadline is coming very fast.

While the first deadline should be the easiest of the HazCom deadlines to meet, training preparations should not be taken lightly – nor should the recordkeeping associated with the training. It is likely that once December 1 comes and goes, OSHA will be vigilant in verifying that training has been completed on this important first deadline.

Regardless of how employers plan to handle the training, it is our strong recommendation that employers get the training done sooner rather than later. Already we and others are seeing updated labels and safety data sheets entering the marketplace – which means your employees are likely to see the updated formats before the December 1 deadline.

To help employers get employees up to speed on GHS formatted labels and safety data sheets, MSDSonline has launched a new online training course: Hazard Communication 2012 Awareness-Refresher.

This course is for employees that have been previously trained on Hazard Communication, but require additional training in light of the Hazard Communication 2012 updates. Special attention is paid to new Safety Data Sheet and Labeling requirements, as well as an examination of the new Hazard Classifications

Since 1994, chemical manufacturers, distributors and employers that use hazardous chemicals have been operating under an HCS that has been little changed. And in that time, many have seen their hazard communication program grow lax and outdated.

2013 and GHS deadlines gives everyone a reason to refresh their hazard programs in ways that can benefit the entire organization. As we’ve mentioned before, getting employees trained early is a win/win for employers.

First, it mitigates employee risk by giving them the tools to understand the new hazard symbols and warnings. Second, it enables your employees to assist management in keeping a look-out for updated safety data sheets, which must be added to the employer’s safety data sheet library and scrutinized against the older documents they replace, to see if any additional hazards have been identified.

Beyond Deadlines

Think about your current workplace hazard communication program. What would you change if you could? Have you slipped out of compliance? Do you know every hazardous chemical in your workplace? Do you have a safety data sheet for each chemical? Are you doing a good job of training and retraining employees as they move throughout the various tasks and chemical exposures in your facility?

GHS may be the catalyst; however, the opportunity in front of safety professionals related to chemical management goes beyond meeting training deadlines. As part of GHS adoption, covered employers, manufacturers, and distributors will likely need to extensively update their hazard programs, including the way they label secondary containers.

Safety professionals might do well to think of GHS as an opportunity to engage leadership in a revamp of the entire workplace norms around chemical safety. Certainly, as budgets are adjusted, now could be a good time to secure better funding around critical chemical safety tasks.

Here is a GHS related to do list, including action items for 2013:

  • Designate GHS Transition Leader
  • Get Educated on GHS
  • Inventory Chemicals (Physical Inventory)
  • Check Inventory Against Safety Data Sheet Library
  • Acquire Missing MSDSs
  • Safely Dispose of Chemicals No Longer in Use/Needed
  • Archive MSDSs No Longer Used
  • Train Employees on GHS Label Elements and SDS Format
    • December 1, 2013 Deadline
    • Track Training (Recordkeeping)
  • Prepare for SDS Churn
    • Compare incoming safety data sheets to existing ones – note hazards
  • Get Secondary Container Labeling Strategy
    • Re-label Secondary Containers
  • Train Employees On Any New Hazards
  • Update Written HazCom Program
  • Meet SARA/EPCRA Reporting Obligations
  • Stay Current on GHS

As mentioned at the top of this post, MSDSonline has a FREE downloadable GHS Compliance Checklist.

Eyes Wide Open in 2013

An annual tradition in my family is that on the drive back to Chicago from visiting my wife’s family in Missouri during the end of year holidays, we do a recap of the previous year and an inventory of challenges and opportunities for the upcoming year.

We talk budgets, school, work, personal and professional priorities and concerns…and each time we start the conversation, we feel apprehension about uncovering old wounds or confronting challenging issues. However, without fail, by the end of the conversation, having a clear-eyed view of our circumstances, no matter how dire, we all feel better. More importantly, we put ourselves in a position to be able to make substantive changes that most often lead to better outcomes than was originally feared.

Knowing the truth about your world is the first step toward making any necessary changes.

Talking to many safety professionals over the last year I have been greatly encouraged. There is an awakening happening in this country to issues related to chemical safety. Many folks I’ve talked with have said GHS is the push they’ve been looking for to get back into compliance. They know they have let some things slip, like keeping the MSDS book up-to-date, or documenting training, and they are excited about getting things right.

Unfortunately, I’ve had a number of conversations with folks who feel like they are out of the spotlight enough that they don’t really need to keep current with HazCom. It often seems like it’s a business consideration on their part – not wanting to put any “unnecessary” resources to a standard they may never get called on.

Setting aside the consequences such attitudes can have on employee safety, it’s just bad business. Trained, well-informed employees are more productive. Compliant systems are efficient systems, and efficient systems waste less time and money while producing superior results. Products derived from safe and sustainable practices are more marketable and attractive to the marketplace.

Our hope at MSDSonline, whether you are a customer or not, is that your 2013 is a good one and that you navigate its many opportunities and pitfalls with eyes wide open.

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