OHSA implemented GHS as part of its Hazard Communication System (29 CR 1910.1200) back in March of 2012. The full conversion is not until June 2016, but there is a phase in process that you should already be aware of. The first deadline set by OHSA was December 1, 2013. This was sort of a basic-training for employees to learn what information is on GHS labels, SDS sheets and how to recognize the new pictograms. Imagine opening the back of a truck, ready to unload its contents into your facility and you see these strange labels on your drums. These are MY drums aren’t they? They have strange looking labels on them, with familiar but slightly different pictograms, along with a few new ones. You reach for the MSDS to see just what the heck you are looking at, only to find something called a SDS. Hey, what happened to the “M”? Wow, there is a lot of information on this SDS. Quit looking for the “M” and Behold! The future.
Learning a new language can sometime s be difficult, but understanding GHS is not. The first training deadline was just a fair warning, saying “Hey! I’m here, and this is what I look like. Oh, and by the way, you are going be seeing a lot more of my kind in the future” That’s right. Did I mention, it the law? Yes, this short introductory training is required. This is Hazardous Materials training. Do you have new chemicals in the workplace, new processes, new hires, even a new classification and labelling system alters your existing Hazard Communication Program. Employers are required to train their workers when something is new, or has been changed. Many companies have already begun using the GHS system, ensuring that you will be seeing these labels in the near future.
The next deadline is June 1, 2015, a little over a year away yet still plenty of time for us to adapt. This is more of a hard deadline. Chemical manufacturers, importers and distributors will be required to classify their chemicals according to GHS and produce GHS compliant labels and SDS sheets. There is a 6 month grace period ending December 1, 2015 allowing distributers to get rid of old-labelled inventory. In order to avoid bottlenecking after June 1, 2015 any new chemical that is produced should be GHS compliant ensuring you can remove all old-style labelled products by December. So, by December 1, 2015, everything should be GHS compliant.
It’s not too late to get trained! In order to comply with OSHA’s HazCom rule this basic training is required. HazCom violations have been one of the most cited violations over the past two years. Another common citation is “documentation”. This is what they call “low hanging fruit” or “easy pickings” for OSHA compliance inspectors. They target one of our biggest weaknesses: Organization. They WILL ask to see your GHS training certificates for each employee. Don’t get cited for choosing NOT to follow the rules. If you have anything to do with Hazardous Chemicals, then you have heard of GHS. You’ve heard of OSHA haven’t you? Well, GHS is part of OSHA. If you don’t follow GHS, then you don’t follow OSHA!
Just like the basic hard hat and steel toed shoe rules in place for workers safety, HazCom/GHS is there for a reason. HazCom is short for: “Hazard Communication” which simply means to ensure you are communicating potential hazards to your workers. If you don’t know how to read the GHS labels or understand the pictograms, how can you be sure you are handling this hazardous material the right way, or wearing the proper protection? The rules have changed a bit. If you don’t know the rules, you could be seriously injured. If you don’t have the proper training you will be cited, and citations cost money. Even if you missed the December 1, 2013 deadline don’t let it get away. You still need to be trained on GHS! A few months late in getting trained? Well, nobody’s perfect. 16 months late in training? Now that’s low hanging fruit.
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