Over and above the GHS

HCS over and above GHS…

It is interesting to note that there are some areas where OSHA’s HCS requirements go beyond the GHS.  We have all been pretty sure that the GHS is the instigating force behind all the HCS changes.  However, the GHS does not call for a written HCS program OR any additional training.  OSHA however, remains clear that both a written HCS program AND additional training will be required. These two stipulations are clearly in-line with the HCS as it stood previously.  OSHA has always been clear that training is imperative when it comes to the employees right-to-know.  The new additions that stem from GHS do not in any way deflect the need for training.  And perhaps, because we have had so many years with an acting system, they are even more important now.  Clearly, the timing is a little tricky.  We are all still waiting for the new SDS's to be made available.  Once we have those, final training can be implemented.  Until then, employees must understand the differences and the applications of the newly updated HCS will need to be trained in such.  OSHA works hard to insure the safety of American workers.  And this instance is no different.   



This information is offered for evaluation and discussion only.  For more information contact your local OSHA representative or go to http://www.osha.gov/dsg/hazcom/index.html