1. Deadline reminders
Use the table below, as developed by OSHA, to remind managers that HazCom GHS will evolve during the next couple of years. Employee training sets the stage for more activities to come.
2. Training statistics
You should add quantity and quality information to your training efforts. Consider addressing these points to management:
- How many employees were trained in total and by business/work area
- Methods used to ensure employees comprehend the information
- Snippets of employee feedback on training e.g. survey results, verbal comments, and/or perceptions
Remember, management may be keenly interested in whether any problems are anticipated. Because of GHS are employees more or less likely to complain about chemical exposure in the future? Be ready to provide a couple examples of how management may alleviate employee concerns.
3. Global view
Whatever you told management before about GHS, now is the time to reinforce what it is. A quick visual clue will help. Take a screenshot of earth from Google Earth. Explain that approximately 70 nations now have fully implemented GHS. Next, hover above your plant site with Google Earth and then drop down to Street View. You may be able to show this online. If not, just take a screenshot and place into a PowerPoint slide. The dramatics show how new technology, including GHS, works to help connect everyone together. Don’t be surprised to learn that many managers have never seen the plant site from a Google Earth view.
4. Hit the BRICS
BRICs nations – meaning Brazil, Russia, India, China and South Africa often hold a keen interest among business folks. Brazil and Russia are expected to become the world’s dominant suppliers of raw materials. China and India are expected to become the world’s dominant suppliers of manufactured goods.
Briefly mention to managers that Brazil, Russia, and China implemented GHS before the U.S. India should have major portions of GHS implemented sometime in 2014. If time permits, briefly mention that New Zealand, Australia, South Korea, Thailand, Japan, and Vietnam have fully implemented GHS. No need to mention Europe. You may keep track of what nations are doing with GHS at http://www.ghslegislation.com/.
5. GHS logic
Figure I above is the GHS logic as described by OSHA. Summary Points to the right are examples of what you may add to stir discussion among management. You may recreate this view easily in Microsoft Word using tables. Use <Insert> <SmartArt> to create the pyramid. Place grouping into your PowerPoint for show. Again, add your own Summary Points. Remind management that new SDSs, with expected expanded information such as specific type of PPE (material construction, thickness, etc.), will require an evaluation by safety to ensure adequate protections. This comment reinforces to management that safety, and by extension, management, cannot sit on their hands as GHS evolves.
6. GESTIS Substance Database
Put the free GESTIS Substance Database app on your Apple or Android based smart-phone. From the Substance List of about 8,500 substances, have a manager randomly pick a letter and then randomly pick a chemical. Pass around the example, allowing managers to pull down through the data, to demonstrate how easily GHS classification and information may reach the masses.
7. Risk management
From the GHS logic figure, confirm management’s risk management strategies for safe use of chemicals. Ideally, you should encourage the company to adopt ISO 31000:2009 risk management strategies, if they haven’t already done so.
8. CO risk management example
Should management adhere to the TLV that is beyond OSHA compliance or go even further if a DNEL exposure limit appears on an SDS? Here’s an example.
9. CMR risk management example
If management is sophisticated, use the table below to further explore risk management strategies. The table starts with the common understanding of an unstable explosive, applies the most restrictive cut-offs for health hazards and is the cross-over into public health. Only the hazard classes within the table contain the GHS precautionary statement “obtain special instructions before use.” Ask management “what special instructions should we give employees?”
10. Ask for something
GHS is a big evolving issue. You will need something from management to make it work. Shortly after training is when you should ask for something more.