Complying with GHS
Many people assume that because the revised HazCom standard went into effect in May 2012, along with the first deadline to train employees on the formatting changes to labels and Safety Data Sheets (SDSs) was December 1, 2013, all of the new SDSs must be ready and waiting. This is not the case, nor is it likely to be for several years.
Chemical manufacturers and distributors actually have until June 1, 2015, to update their SDSs. Before they can make the update, they must first reclassify their chemicals using specific Global Harmonized System (GHS) criteria that the Occupational Safety and Health Administration (OSHA) has adopted for health and physical hazards.
Once You Get Your New Safety Data Sheets, You Have Some Work to Do
Unfortunately, as employers, you do not have the option to sit back and wait for all the chemical manufacturers and distributors to finish all of their work before you begin yours. Throughout the process, when an update is made to an SDS, you will have to pay attention. It is in that task that a good electronic SDS management solution can really help. A good system can track what's new, easily toggle between versions, and update and deploy documents quickly across the organization.
Here is a simple plan to help employers to be successful over the next few years:
- Do a chemical inventory. It's hard to be compliant and keep up with changes if you don't know what chemicals are in your facility today.
- Make sure you have a current SDS for every chemical on your inventory.
- Properly dispose of chemicals you no longer need, that are expired, or that are otherwise obsolete.
- Make sure any employee who is on the frontline and could conceivably be the first person to receive a SDS knows about the updates and is on the lookout for SDSs. Chemical manufacturers are only required to send an updated document with the first shipment or the first shipment after a change has been made.
- Make sure frontline employees know what to do with SDSs when they are encountered.
- Compare new SDSs against the older ones as they enter the facility. Check to see if there are any new hazards, instructions, or safe handling recommendations.
- Train employees on new information and hazards required.
- Have a plan for archiving older documents if that is how you comply with OSHA's 29 CFR 1910.1020-Access to Employee Exposure and Medical Records Standard.
- Update your SDS library.
As part of IEC’s top-notch workplace safety program, IEC has compiled GHS resources. These resources will help ensure that you and your employees are fully trained in HazCom. These resources include toolbox talks, OSHA quick cards, and presentations. IEC members can access all the GHS resources at www.ieci.org/workplace-safety/ghs-resources.
Jack Otting is Safety/Training Director for Excel Electrical Technologies, Kennesaw, Georgia.