GHS ...is there a defining line of application?
This writer continues to hear statements that infer the GHS is a stand-alone regulation. This is incorrect. The Globally Harmonized System of Labeling Hazardous Chemicals was adopted Internationally. Where and how it effects us in the United States is the question here. OSHA has chosen to incorporate the GHS into the existing Hazardous Communication Standard.
The HCS was publicized in the 80's. It must be made clear, that the HCS is a workplace regulation. This would seem obvious, since OSHA is the Occupational Safety and Health Agency. It is difficult to understand why or how any reader of the HCS could ascertain that the GHS additions somehow alleviate business from having to comply with these changes. Yet, this is exactly what many individuals continue to say. This is disturbing on many levels, not the least of which is worker safety. The changes to the labeling are the biggest and most compelling reason for all employers to sit up and take notice. To say that the GHS is only a training issue is simply...well, over simplified. In the Revised HCS that was published earlier this year, OSHA states in more than one section that ALL WORKPLACE LABELING shall comply. The only labels the rule states that don't have to be labeled are
those that are small secondary containers meant for "immediate use".
The
rule states -- see (f)(1)(i) thru (f)(1)(v) -- that every container, save these "immediate use" containers
must be labeled with the following:
Product Identifier, Signal Word, Hazard Statements, Pictograms and
Precautionary Statements. This information will be found on your SDS
and should be supplied by your Chemical Supplier.
Rest
assured, Safetycal is hard at work putting together all the labeling
products you will need to meet the rule head-on with confidence. For
now, send us an email to be put on our announcement list when these
products are ready to launch you into compliance. Visit us at www.safetycal.com
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
