According to a recent study conducted by Actio Software Corp., roughly 50 percent of environmental, health and safety (EHS) professionals surveyed indicated that their company fails to meet all of the GHS requirements outlined under OSHA’s revised Hazard Communication Standard (HCS) in 2012.
The survey, which was completed by 108 EHS professionals representing various industries in April 2016, was designed to gain a better understanding of the readiness (or lack thereof) of organizational alignment with OSHA’s HCS and the GHS.
“We knew there were a decent amount of companies having a difficult time meeting OSHA’s GHS requirements heading into the final June 1 deadline,” explained Chris Nowak, director of business development at Actio Software Corp.
“By conducting this survey, our goal was to gain a better understanding of what type of companies were struggling to become GHS compliant, and learn what type of obstacles were preventing these companies from meeting OSHA’s HCS requirements.”
After reviewing the results, it’s safe to say that the current number of GHS compliant companies in the United States is far below what the administration envisioned when it decided to align the HCS with the GHS in March 2012. Out of the 50 percent of participants who claimed their company was not yet GHS compliant, 48 percent estimate that it will take their company at least another 120 days to complete OSHA’s HCS obligations.
What’s Preventing GHS Compliance?
According to participants of Actio’s GHS Readiness survey, securing updated SDSs from suppliers tops the list of obstacles preventing companies from meeting OSHA’s GHS requirements. Interestingly, representatives from both GHS-compliant (34 percent) and non-GHS-compliant (30 percent) companies identified the ability to obtain updated SDSs as the biggest challenge associated with making the GHS transition.
In addition to obtaining updated SDSs, other challenges like authoring new SDSs, reclassifying chemicals and finding a suitable GHS labeling solution provider impacted the survey participant’s ability to meet OSHA’s HCS requirements.
Investing In the GHS
Since OSHA's HCS alignment with the GHS is expected to impact more than 40 million workers in more than 5 million workplaces across the United States, businesses from a broad range of industries have invested time, money and resources in order to meet OSHA's updated HCS.
But where did companies spend the most money, and why?
According to the GHS Readiness survey, the overall majority of respondents indicated that their company spent less than $50,000 (65 percent of GHS-ready companies vs. 75 percent of non-GHS-ready companies) leading up to the June 1 deadline.
As indicated in the survey, the majority of these investments were earmarked for EHS management software, GHS labeling equipment and third-party support services such as employee training and SDS sourcing.
With the majority of respondents citing the ability to secure updated SDSs from vendors – the biggest challenge in making the GHS transition – it's not surprising that purchasing EHS management software that helps secure, track and maintain SDSs was the single biggest investment made by companies looking to comply with the GHS.
Complying with the GHS
While there are certainly skeptics out there, like the 24 percent of survey respondents who believe that OSHA’s alignment with the GHS will never have a positive impact on business, regulatory compliance and worker safety continue to drive adoption of the GHS among EJS professionals.
With the overall majority (62 percent) of survey respondents listing regulatory ﬁnes and penalties as the biggest risk of failing to comply with OSHA’s HCS, it will only be a matter of time until compliance with the GHS is the norm. Until then, the following best practices can help your company manage and maintain GHS compliance:
- Conduct regular chemical inventories: By performing a chemical inventory, your staff will be able to verify that they have the most recent SDS available for all of your hazardous chemicals. Regardless of whether or not the SDS is in the GHS format, having the most current information will make it easier to track and maintain your SDS library.
- Establish consistent communication with suppliers: At the end of the day, employers are responsible for making sure that their employees have access to the most updated SDSs. With this in mind, employers receiving non-GHS-compliant SDSs from suppliers should get in touch with their vendors to request GHS-compliant SDSs. If for whatever reason, the vendor is unable to supply the correct format, the employer should contact the local OSHA office in an effort to secure the proper SDS.
- Help employees transition from awareness to understanding: As part of a compliant hazard communication program, employers need to train employees on any newly discovered hazards listed on safety data sheets and labels so that they are aware of dangers and know what procedures to follow if contact is made. With this in mind, employees should host regular training sessions that focus on helping employees gain a solid understanding of the elements found on GHS labels and SDSs including, but not limited to, signal words, pictograms and first aid measures.
- Keep an eye out for updated SDSs: Making sure employees are trained on the new GHS formats will help them quickly identify updated SDSs. As new SDSs enter the facility, trained employees will be able to spot GHS SDSs and use them to update binders and create secondary container labels to ensure that your company remains compliant with OSHA’s HCS.
- Leverage technology: There are many affordable SaaS and cloud-based EHS software solutions on the market today that can help manage your company’s GHS responsibilities. Many of today’s chemical management solutions can help save business time and money by automatically distributing updated safety data sheets to different locations in a facility and allow users to filter by GHS and other criteria so you can get a quick snapshot of your GHS transition progress.
As one of the biggest transitions in modern day manufacturing, it’s going to take time until we start to see the benefits of OSHA’s HCS alignment with the GHS. The fact is, regardless of how much time it takes to get everyone on the same page, aligning OSHA’s HCS with the GHS as a means to protect the health and safety of our workforce is worth doing.
About the Author: Chris Carragher is the communications director for Actio Software Corp., a leading SaaS provider of chemical management and regulatory compliance software designed to improve workplace efficiencies while protecting the health and safety of employees. For more information, call 866-522-8102.