GHS and STATE COMPLIANCE

How do State plans stand up?
There are 27 States and U.S. Territories that have OSHA approved occupational S & H plans.  They are Alaska, Arizona, California, Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Nevada, New Mexico, N Carolina, Oregon, Puerto Rico, S Carolina, Tennessee, Utah, Vermont, Virginia, Washington, Wyoming, Connecticut, Illinois New Jersey, New York and the Virgin Islands. 
Even though these States have currently approved HCS regulations in place, they MUST revise their standards to include the GHS modifications to the HCS.  The adoption needs to take place within six months of the publication of the final rule by Federal OSHA. 
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 

GHS FEASIBLITY

Is GHS really feasible? 
 
One of the requirements for any OSHA rule is that it be feasible.  The added elements of the GHS to the revised Hazard Communication Standard are in fact, very feasible.
While the modifications of the labels and the format of the SDS must both be adjusted to fit these new elements, employers will be able to use their current methods of training to comply.  Yes, the content of the training changes.  Yes, there are new pictograms to understand and there is a format change to the display of the information.  Where in the past an employee may have been able to gather PPE information at a quick glance, they must now read the text as provided on the label before beginning their task.  However, the fact remains that employers’ must train, must label and must maintain accurate and up to date SDS on file for all chemicals within their facility.
Remember, the updated HCS Rule states the following:
“Labels are intended to provide an immediate visual reminder of chemical hazards.  Whereas labels in the past could be presented in a variety of formats using inconsistent terminology and visual elements, labels prepared in accordance with the requirements in this final rule will be consistent.  Standardized signal words and hazard statements attract attention and communicate the degree of hazard.  Pictograms reinforce the message presented in text and enhance communication for low-literacy populations.  Precautionary statements provide useful instruction for protecting against chemical-source injuries and illness”
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.
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 

Opt - out of the GHS?

Can your company "opt-out" of the HCS/GHS updates?

The short answer to this question is "no."
While OSHA did receive comments that certain companies should be allowed to opt-out of complying with the revised GHS portion of the HCS, other commenter’s argued that having a multiple systems in place would undermine the implementation of the rule.  OSHA agreed that multiple rules would cause confusion and that allowing even one company to deviate would affect other companies.  OSHA also acknowledges that small chemical companies would incur burdens not necessarily felt by larger companies.  However, employees in the end-user workplaces deserve to have access to the same chemical information regardless of the size of the generating company.  OSHA, therefore, determined that in order to achieve a consistent standard across all companies ALL businesses will be required to adhere to the revised HCS.
Remember, the updated HCS Rule which was then published earlier this year, has clear stipulations of GHS additions which state the following:
“Labels are intended to provide an immediate visual reminder of chemical hazards.  Whereas labels in the past could be presented in a variety of formats using inconsistent terminology and visual elements, labels prepared in accordance with the requirements in this final rule will be consistent.  Standardized signal words and hazard statements attract attention and communicate the degree of hazard.  Pictograms reinforce the message presented in text and enhance communication for low-literacy populations.  Precautionary statements provide useful instruction for protecting against chemical-source injuries and illness”
This would seem a pretty clear statement regarding the format of ALL Hazardous Material Labeling in the workplace. 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.
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 

GHS - How is it going to affect us?

How do we adapt to this new rule?

OSHA clarifies their view on how we will be affected by this new rule by stating that "employees whose only exposures to hazardous chemicals result from their use of the chemical" the affects will be fairly minor and consist mostly of becoming familiar with new labeling.  However, for those companies that manufacture chemicals, the standard packs a little stiffer punch.  All chemicals will need to be reclassified in accordance with the new system.  This simple statement carries a heavy weight for the chemical industry as a whole.  One can assume this includes companies that manufacture chemicals as a bi-product of their process.

That is not to say that OSHA is insensitive to the enormity of this task, which is why they have allowed a fairly long phase-in period.  And remember, this is not just US companies that must comply.  All imported chemicals must also carry the proper classification and labeling before they reach our docks.

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