GHS Standard Scheduled for Finalization September 2011

1. Chemical Manufacturers & importers will be responsible to classify the hazards associated with their chemicals. Employers may rely on information provided.
2. Labels
   1. Manufacturers or importers of classified hazardous materials will be responsible to ship materials with labeling which includes:
   • Product identifier(s);
   • Signal word (Danger or Warning);
   • Hazard statement(s);
   • Pictogram(s);
   • Precautionary statement(s);
   • Name, address & telephone number of the chemical manufacturer or importer.
   2. Manufacturers or importers of unclassified hazardous materials must include the following on the label:
   • Name of the chemical;
   • Name, address & phone number of the manufacturer or importer;
   • Supplementary information including the description of the unclassified hazard and precautionary measure to ensure safe handling and use.
   3. Solid metals (i.e., steel beams, or metal castings), solid wood or plastic items not exempted as articles (due to downstream use), may have the label transmitted to the customer at the time of initial shipment and not included with subsequent shipments to the same facility unless the label information changes.
      
      This label represents an idea of what some of the new GHS labels might look like. This particular one is being sold by Labelmaster. It appears to incorporate some of the old HMIS label features which is a bit confusing with the new ranking schemes.
      
      Once the new regulations are finalized, the label companies will gear up quickly to meet market demands.
      
      One possible avenue for handling existing chemical inventory labeling is to purchase some “print your own label” software or to utilize some label printing resources already available through Microsoft Office products. The graphics for the pictograms are available for free on Wikipedia.
      
      
      
      
   4. Hazardous chemical containers already in the workplace will need to have the labels added which cover the following:
      • i. Product identifier(s);
      • Signal word (Danger or Warning);
      • Pictures or words which provide at least general information regarding the hazards of the chemicals;
      • The employer may use signs, placards, process sheets, batch tickets, SOPs or other written materials in lieu of affixing labels to individual stationary process containers;
      • Employers as well as chemical manufacturers and importers must revise the labels for a chemical within 3 months of becoming aware of new information.
3. SDS Changes – The Safety Data Sheets will now have standardized sections. This will be a huge help in training and in being able to quickly go to a section for emergency data. The new required format is as follows:
   1. Section 1 – Identification
   2. Section 2 – Hazard Identification
   3. Section 3 – Composition Information on Ingredients
   4. Section 4 – First Aid Measures
   5. Section 5 – Firefighting Measures
   6. Section 6 – Accidental Release Measures
   7. Section 7 – Handling and Storage
   8. Section 8 – Exposure controls/Personal Protection
   9. Section 9 – Physical and Chemical Properties
   10. Section 10 – Stability and Reactivity
   11. Section 11 – Toxicological Information
   12. Section 12 – Ecological Information*
   13. Section 13 – Disposal Considerations*
   14. Section 14 – Transport Information*
   15. Section 15 – Regulatory Information*
   16. Section 16 – Other Information including date of preparation or last revision.
       *Sections 12-15 are outside of OSHA jurisdiction and are non-mandatory.
4. Your HazCom Program will require some minor changes to include:
   1. Reference to SDS
   2. Reference to labeling requirements
   3. Updated training
5. Employers must train employees on the new labels and SDS within 2 years of the adoption of the final GHS rule.
6. New SDS are required by chemical manufacturers, importers, distributors and employers within 3 years after adoption of the final GHS rule.

Since we are in the waiting game you may be asking yourself “what can I do to prepare for the approval of the GHS rule?” I have some suggestions for you to consider:

• Get an accurate inventory of current chemicals on-site. Rather than assign this duty to a single person, why not have a “chemical identification blitz” for one of your Kaizen or improvement projects?
• Once you have an accurate chemical inventory, sort through those vast tomes (your MSDS binders) and archive all MSDS which are not currently listed in your chemical inventory. Remember you must retain old MSDS for 30 years after the last use of the product but that doesn’t mean it has to take up space in your active binder. You can create an archive binder or you can scan them into a database for 30 year retention.
• With the remaining active MSDS, review each to see if they’re already in the new GHS format. Many companies trading internationally have already adopted the GHS format and you may have some SDS in the new format in your binder right now.
• Create a checklist denoting which chemicals have a GHS compliant SDS on file and which ones must be solicited from the vendor. Check online to see if the vendor already has the new SDS available.
• You will need to consider labeling options for those chemicals currently on-site at your facility. Until the final rule is approved, the commercial options are sparse. Still, it’s worth discussion the approach your organization wants to take once GHS is approved. Consider a labeling blitz for a fall or winter Kaizen project. Get everyone involved in identifying containers which need the new labels. Don’t forget spray and squeeze bottles!

Once the GHS rule is finalized, ECS will issue an update with further information. We are considering hosting a regulatory update seminar in the fall. Please let us know if this would interest your organization in handling the required changes.

Environmental Compliance Source, LLC | (812) 945-1541 | Fax: (866) 532-5161 | PO Box to 6849 | New Albany, IN  47150
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