On Oct. 25, 2011, OSHA sent the Office of Management and Budget (OMB) its final rule to adopt the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) as its hazard communication standard (HCS). OMB now has up to 90 days to review and finalize the rule before it is published in the Federal Register by January 2012.
GHS introduces a set of criteria for categorizing the human health, physical and environmental hazards of hazardous substances. Prior to GHS, a substance could have been classified as toxic, non-hazardous or harmful to health depending on which country/tracking block the classification has been made (Canadian WHMIS, EU DPD, etc.). GHS harmonizes these different systems, and new classification criteria could create a higher, lower, identical or new classification for a product compared to the previous system. The new standard also has far-reaching implications for the format of, and data contained within, material safety data sheets (MSDS) and product labels.
In addition, the promulgation of the final rule will affect millions of workplaces and have a profound effect on the supply chain. Upstream, manufacturers and distributors will be required to conform to new safety data sheet (SDS) format and content requirements. Downstream, producers, importers and distributors will have a 3-year transition period to be in full compliance. The proposed rule also includes a provision that requires employers to train all employees on the new label elements and the standardized safety data sheet format within 2 years after the publication of the HCS final rule.
For some, transitioning to GHS has been coined as an “avalanche” or a “tidal wave.” However, if the appropriate tools are in place to handle the transition, the volume and scope of change ahead does not need to be daunting.
In response to these challenges, we developed a five-step program (detailed below), which outlines best practices when developing a GHS transition strategy for a workplace. This guide will ensure a company is ready for when GHS SDS and labels begin to filter down the supply chain. These steps are cyclical, as information will continue to be added and updated as this new requirement is implemented.
Step 1: Sourcing updated GHS supplier SDS
The first step of any SDS management program is sourcing relevant SDS for all hazardous products onsite. What should your company be doing?
Inventory preparation – Accurate inventory management is the cornerstone of any comprehensive SDS management program. Ensure you know what products on your shelves, and that each one has a corresponding SDS.
Make a note of the current classification, labeling and packaging of each substances and mixture. This is important information, as it needs to be compared with new GHS classification when available.
Create a schedule to begin contacting suppliers to request updated documents. Suppliers may send you updated SDS even if you have not placed a new order, so keep a note of these incoming documents to eliminate redundant efforts.
Step 2: Distributing GHS SDS to employees
The second step in the cycle is distributing GHS SDS throughout your company, especially to employees. What should your company be doing?
SDS should be stored in paper and/or electronic repositories that easily are accessible by employees. Having SDS organized in a centralized repository from which each department or location can pull documents will help increase productivity by removing workload duplication. It also yields consolidation and transparency of information across departments and locations.
Incorporate a process to quickly update repositories as new or updated SDS come on site. This could mean photocopying the new SDS and manually putting it into paper binders throughout a plant, or loading it into a local or centralized electronic system.
Prepare repositories and update employee procedures to handle increased volume of incoming GHS SDS from suppliers during transition period.
Step 3: Evaluating SDS changes
Following the receipt of an SDS with GHS information, the third step in the cycle is to review the new SDS and compare with the previous version to evaluate changes. What should your company be doing?
Before any information can be compared and evaluated, you will need to put in place a structured, streamlined process for extracting and viewing old and new information.
Once this is in place, information can be evaluated from each SDS to see if the re-classified products will have any ramifications. The United Kingdom’s Health and Safety Executive (HSE) calculated that it requires an employee 1 hour to review the labels and SDS for each product. This equates to a large expenditure of time and money when performed manually.
Step 4: Utilizing new GHS information
The fourth step in the cycle is utilizing the new information. What should your company be doing?
GHS information was created to improve hazard information available to employees. Exposing simple text to employees as much as possible helps circumvent accidents through proper understanding of the hazards and the required precautionary measures.
All containers should be appropriately labeled. As you move a product from its primary container to a secondary container, labels should be replaced.
Keep abreast of regulatory reporting needs for all products. Regulatory lists never stop evolving. This, mixed with the classification changes of your products, means an extra stringent eye is required to ensure you are aware of all regulatory responsibilities.
Step 5: GHS training
The fifth step in the cycle is to educate. What should your company be doing?
There are three different groups that require training.
Self educate: First and foremost, it is vital that you are familiar with the downstream responsibilities under GHS. Only then will you be in a position to educate other people. GHS is updated regularly, and it is vital to understand new impacts.
Educate employees: Employees should be trained to become comfortable GHS. They should know:
➤ Where to find information on new GHS-formatted SDS and labels.
➤ How to interpret GHS information.
For example, in the United States, GHS classification ratings order of severity are the opposite of current NFPA, HMIS classifications:
➤ GHS (1 = most severe to 4 = least severe)
➤ HMIS/NFPA (4 = most severe, 1 = least severe)
Also be aware of nomenclature changes. For example, in the United States, “MSDS” is replaced with SDS, and in the European Union, “preparation” was replaced with “mixture.”
Educate customers: Manufacturers/wholesalers/retailers may play a voluntary role in educating customers as customers navigate new information coming through the supply chain. Classification clarification may be required for the products they are buying.
While this has been segmented into its own section for explanatory purposes, training is required throughout the transition, so apply this training methodology accordingly.
If your workplace operates in a country that has not implemented GHS, but imports from countries that have, GHS information may appear sooner than expected, which will require earlier training.
Following this five-step program will ensure GHS information is sourced, distributed, evaluated, utilized and understood within the workplace.
Louise Bernstein is a product manager with 3E Co., specializing in the internationalization of 3E Services.