The BIG 3 in the new HCS/GHS
According to OSHA, the three Core components of a Comprehensive Hazard
Communication program are Labels on all containers, up to date SDS and
Training. Just as the Chemical Companies
are responsible for writing and providing new and updated SDS on all chemicals,
and the end users are responsible for maintaining up to date labeling,
employers are responsible for proper training to ensure that employees are well
versed in the new label format.
Understanding the difference between the signal words Danger vs Warning
may seem pretty obvious. However, as
stated in previous posts, the pictograms may require a bit more training and
understanding before employees are clear on the meaning. ANSI Z353.3 states that a pictogram design is
successful if 85% of viewers understand its meaning. That said, some of the pictograms adopted by
GHS scored as lower than 13%. Whether we
agree with the chosen symbols or not, they are here to stay and employees need
to understand their meanings. It should
be said that training has ALWAYS been part of the HCS. OSHA has extensive documentation that
reinforces that these three elements are complementary parts of a well place
hazard communication program as each one of them reinforces the other. With the ultimate goal of this standard being
the employees right-to-know the hazards they face, a strong training program,
consistent labeling of good quality and clear and easy to read SDS simply make
sense.
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
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
