A blueprint for GHS transition
5 tips for implementing OSHA’s new standard
1. Create a transition plan
The transition plan maps out your responsibilities against the GHS time windows (see p.30 for dates). If your own products don’t require safety data sheets (SDS) and are considered not to be hazardous, the process is a bit simpler. In this case, you only need to worry about the updated SDS coming from your vendors and how to train and prepare your own employees about the updated information. Your transition calendar should account for the following requirements:
• Completing a chemical inventory
• Preparing or acquiring training materials
• Acquiring and updating vendor safety data sheets (SDS)
• Re-labeling secondary containers based on the new SDS
• Training your employees
We recommend completing each step at least six months prior to the actual deadline. For example, the employee training deadline is December 1, 2013, so you should complete your training by June 1, 2013. Similarly, for the three-year full transition date for labels and updated SDS, give yourself at least a six-month runway for any issues that may come up. However, acquiring and re-distributing updated SDS will continue well past the transition.
2. Perform a chemical inventory
An accurate chemical inventory is the foundation for your GHS transition plan. Without an accurate inventory, not only do you risk not having the correct SDS for all of the materials in your facility, but you could also spend a lot of time and money updating documents for materials that are no longer present.
Executing a solid chemical inventory is an
article of its own, but let’s touch on a few important elements:
a. Determine your end goal. Is it only to ascertain what materials are located where in the facility, or is it also to understand how much of the material exists in the facility?
b. Be able to reconcile the materials in your site with the SDSs you need for hazcom. Log down product code, manufacturer and other identification information to insure you can match the name on the container with the proper SDS.
c. Make sure it is repeatable. By barcoding, labeling and utilizing a chemical management system that lets you reconcile these at the end of the inventory event, you can minimize time, increase accuracy and insure compliance.
3. Acquire, update and manage new incoming SDS
First, decide if you want to do this yourself with your own company resources or outsource this task to an SDS services provider. Current SDS software and service providers already have catalogs of materials and safety data sheets and an established process for acquiring, updating and managing SDS.
Make sure your outsourced vendor has updated their software to handle the new GHS data and classifications. Since GHS was adopted differently in different regions of the world, hazard classifications may vary, and you may see many more versions of SDS depending on the country classifications and native language requirements. Your SDS software vendor’s system should support a multi-language, multi-country approach.
4. Update workplace labels
Under GHS, labeling requirements are specified for signal words, hazard and precautionary statements, and pictograms. The use of pictograms is a significant change for U.S. workplace labeling as well as the hazard rating system, which is numerically inverse from current NFPA and HMIS rating systems.
Guidance for labeling requirements is available on the OSHA website, as well as the UN GHS site. Additionally, you can contact your SDS management provider for insight.
5. Conduct employee training
Employee training will be a key component of your overall GHS approach and should incorporate information as it is introduced into the workplace. Employees and emergency responders will need to be trained on all new elements they will face, from hazard statements to pictograms. Bear in mind, if products are imported from countries that have implemented the GHS prior to the U.S., your employee training may need to begin earlier than expected.
The most important changes to communicate will focus on how to read the updated labels, how to interpret the new pictograms, and what the various signal words, hazard statements and precautionary statements mean. One potential source of confusion lies in the way GHS classifies hazards. In current NFPA and HMIS label ratings, “4” is the worst and “1” is the best (least hazardous). However, in GHS nomenclature, “1” is the worst. Be certain employees are clear on the rating changes.
While it may seem overwhelming at first, defining and following a structured plan for your GHS transition will promise the most success. Establish your transition timetable, create your implementation calendar, and consider the guidance of industry resources and peers in your efforts.