For some time now, safety professionals have been expecting the U.S. adoption of the Globally Harmonized System (GHS) to make some pretty significant changes to OSHA’s hazard communication standard. Since the mid-2000s, OSHA and other agencies have been discussing and hosting hearings on GHS and revising the hazcom standard. Now that GHS finally is here with all provisions and deadlines outlined, we can expect a focused effort by safety professionals and OSHA to ensure all requirements and deadlines are met.
The question most EHS professionals ask about the changes underway is: “What do I need to do now to implement hazcom 2012?” It’s a bit of a loaded question, and it depends on the specific needs of an organization. At this point, it isn’t as much a matter of “getting ready” as it is a question of “How am I going to meet all requirements and deadlines?”
The only constant factor every organization must take into consideration is time. By Dec. 1, 2013, OSHA is requiring that all employees be trained on the update to the hazard communication standard, and by June 1, 2015, organizations must be compliant with all modified provisions of hazcom 2012. What you do from here on out will determine if you are successful in hitting the deadlines. But don’t let those seemingly distant dates deceive you – those deadlines can sneak up on you if you aren’t prepared.
How Companies Are Preparing
The first step in approaching GHS is to create a transition plan and start allocating resources directly to your organization’s GHS transition efforts. With that in mind, EHS departments must balance their current workload with everything that needs to be completed to ensure compliance with GHS. This makes putting a comprehensive plan in place all the more valuable to your organization’s successful transition to the new provisions.
Your transition plan should account for:
A timetable – While the dates are set as to when everyone must comply with HazCom 2012, you can control your internal timetable and delivery dates. An evaluation of your internal resources will help to determine schedules and deliverables or if additional investments in personnel or software are necessary in order to hit your goals. Allow for a 6-12 month buffer before each deadline to account for unexpected roadblocks, either internal or external.
Training – You have just 15 short months until your employees must be trained. Compiling training materials now ensures your team will be better prepared and ready to train your current and future employees on new pictogram definitions, signal words, hazard classification categories and H&P statements, along with the new SDS format.
Updating and managing safety data sheets (SDSs) – Plan on updating the majority of your current SDSs as your vendors will start supplying you with safety data sheets much more frequently than you have been accustomed to in the past. Are your internal systems and personnel adequate to support the avalanche of updated safety data sheets flooding your department?
Performing a chemical inventory – This is a valuable tool to assist you and your employees. With an inaccurate inventory, you risk not having the correct SDS or acquiring an SDS for a material that is no longer present, which costs time and money.
Re-labeling secondary containers – Labeling requirements have changed. Changes include the fact that pictograms must be outlined in red and chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement and precautionary statement for each hazard class and category.
The Goal of GHS
The goal of GHS is to create consistency and harmonization of chemical safety documents and hazard communication. First and foremost, hazcom 2012 is a tool to protect employees and anyone handling or exposed to hazardous materials in their workplace. Aside from enhancing worker comprehension of hazards to provide faster and more efficient access to information on the safety data sheets, businesses need to understand that GHS not only is a function of safety, but also a function of business.
Though designed for safety, GHS establishes processes that assist businesses in streamlining their operations. Variations of previous standards often created confusion and the need to author a multitude of documents based on agency, country and a host of additional regulations. Investing in a unified a system globally reduces trade barriers created by various health and safety agencies harmonizing with systems around the world, opening up new opportunities for expansion.
With consistent chemical data and information, your organization also can reduce risk and improve compliance. Indexing data from SDSs will allow organizations to better leverage information to improve risk management programs. This information also can be used for sustainability initiatives, influencing everything from how a product is developed to cross-referencing regulations when entering a new market and analyzing everything from production methods to chemical and environmental impacts.
The “right to understand” is the intent of hazcom 2012. A work force that better understands the hazards presented by a material creates a safer work environment, which benefits employees and businesses. Through training programs and systems that improve the way chemical and hazard information is presented, GHS will have a direct effect on the prevention of workplace accidents and illnesses caused by hazardous materials.
OSHA estimates that the revised hazcom standard could prevent 43 fatalities and 585 injuries and illnesses each year. Money saved from these reductions could total $266 million per year. Furthermore, chemical cost reductions and productivity improvements are set to equate to $585 million per year in costs savings. Overall, OSHA estimates a net annual saving of $754 million per year. Implementing GHS, meanwhile, only costs 12.8 percent of the total savings.
So what do we expect from hazcom 2012? You can expect the new standard to greatly contribute to creating a safer, more efficient working environment and lead to potential cost savings, as well. While the GHS transition may seem overwhelming and taxing to an already full workload, organizations that employ the right mix of people, process and technology should have plenty of runway to adopt the updated standards on time or even ahead of schedule.
Scott Palubinsky is a marketing communications manager with SiteHawk, a leading cloud-based SDS and chemical data management solutions provider offering a complete approach to SDS management, chemical inventory tracking and product sustainability initiatives.