Can NFPA be combined with GHS and still be compliant?

Can you combine NFPA or HAZCOM style Labels with the GHS format?

This is a re-post...because it needs to be said again... 
 
Most of the concerns heard by us in the labeling industry lean to the issue of incompatibility with current labeling systems.  We have all spent many years refining the labeling and training in regards to HCS.   We have trained employees in regards to the numbering system, PPE, Spill Management and Emergency Response.  

Now, along comes GHS... The biggest concern we hear time and again is the difference in the numbering system AND the adding of a host of new symbols to learn.  We have also been asked repeatedly if it is possible to combine the two systems (NFPA & GHS or HAZCOM & GHS).  Since there is no straight forward language within the regulation that allows for this, we cannot, at this time, endorse the idea. The biggest concern of this author is that while it would be easy enough to incorporate the new symbols into a design that combines the systems, the fact is the hazard ratings from the GHS rule are in direct opposition to those of either of the other commonly used systems.  That said, OSHA nor GHS requires that the numbering system from GHS be listed on labels or signage.  However, the mere fact that they are in opposition can only give one pause.

It would seem the path of least resistance to simply phase out old systems, commit to training and re-labeling with the new format and maintain consistency in the labels that employees and handlers of the chemicals have to work with.  In the end, isn't this the least confusing?  After all, remember all the uphevel the initial HCS caused?  In retrospect, those issues were all addressed and employee safety was the winner.  It can be again.

Next week's topic....
Canada and GHS

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 



  

Workplace Containers and the GHS

 To label workplace containers..or not to label...is there really any question?
OSHA's GHS Rule plainly states that employers may use signs, placard, process sheets, batch tickets or even operating procedures in lieu of affixing labels to individual containers as long as whichever method is chosen meets the required conveyance of information and written materials are available to employees in their specific work area during each work shift.  This is not far off from the original HCS.  However when we refer back to the workplace labeling section, the new rules states that the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged and or marked.  Symbols and statements all need to be present in accordance with the new system.

This brings to mind a previous topic regarding NFPA or HMIS systems and the compatibility of said systems.  It would be worth considering the option of combining them IF the numbering systems were congruent.  Since, at the time of this writing they are not, we are looped back to the original question. 

Next week's topic...
Can labeling systems be combined with GHS?



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 

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