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