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Hazard communication 2012 & GHS transition
 
The mere mention of OSHA's changed Hazard Communication standard which includes GHS (Globally Harmonized System) may cause some of us to wince simply because the old system has been in place for so long, and change is rarely easy. Thankfully, OSHA is cushioning this transition with feasible deadlines for compliance. Mark your calendar so you accomplish compliance goals before these dates:
 
12-1-2013     Train employees on new labels & SDS
06-1-2016     Update labels, complete training and update written program
 
For chemicals manufactures, distributors, and importers
 
06-01-2015      Comply with provisions, except can ship under old system until December 1, 2015, which gives distributors / importers time to update

 
For ESH personnel who want to ensure their company transitions into compliance, here are some of the steps that can make this journey easier.
 
1.      Review your site-specific written program
a.       If you used definitions or took part of the text from the standard, you will probably need to change the language in the program.
b.      The label section will need to reflect the new labels that are required – internal and from the manufacturer
c.       MSDS language will now be SDS – they dropped the “M”
2.      Labels
a.       Look at your in-house printing system and determine if you can accommodate the new format. A lot of folks are already offering good systems to make in-house labels.
b.      Think about new posters to help inform your employees
3.      Safety data sheets
a.       Will your current system accept the new format?
b.      Are you required to develop SDS – then start now
c.       Recognize that the hazard class and categories will be new to employees, so think about how to best communicate this to them.
d.      If you use HMIS or NFPA, the numbers are opposite - so it is critical to communicate what these systems are saying to us;
            HMIS and NFPA uses “4” for severe, while GHS uses “1” as severe
4.      Training
a.       The best tool to help with understanding this system is through the use of consistent training information, video clips and signs/posters
b.      Check out our GHS transition presentation – it’s yours just for free to help get you through this transition. 
 
Remember – the same four parts that have always been the cornerstone of Hazard Communication have not been replaced. The plan is that GHS will update information about every two years and OSHA will determine what items may need to be amended. Look for some changes in other OSHA regulations; PSM, flammable and combustible, and chemical specific standards to align with the new formats. Other countries that have adopted GHS are currently in the process of phasing in the GHS components.