Time Flies …
There are fewer than 100 days left until the big June 1 deadline. Will you be ready?
It is hard to believe that it’s been almost two years since OSHA announced the integration of the Globally Harmonized System of Classification and Labeling (GHS) into their hazard communication regulations 29 CFR 1900.1200. Since then, many countries have also published their regulations, including Canada, with their recent announcement about WHMIS 2015.
I hope the June 1 deadline for safety data sheet and label conversion is not news to you. Most companies should have their documents and labels in progress, if you don’t, better get started! You have a lot of work ahead of you.
I don’t know if everyone understands what a huge undertaking the conversion of an MSDS to an SDS is. The research alone to get the data needed for the classification can take hours. The health hazard data is often hard to find, and confusing. Finding quality, reliable data is key. Don’t take short cuts.
Once you have the data, interpreting it is another matter. STOTs are especially difficult. But, once you finally have the classification you need, the label phrases and SDS are easy! If you have not taken a class on GHS classification, it is a must, if you are the one doing the work! Our class not only discusses the actual classification criteria for Continue Reading…
Which way do I go, George?
John Steinbeck’s novella “Of Mice and Men” is often a required reading for many school children. Though published in 1937 about a story of migrant workers in the Great Depression, it has many themes that are still powerful today. What many don’t know is that one of Steinbeck’s characters from this story is parodied in a classic Looney Tunes cartoon.
Of Fox and Hounds
In this cartoon, Willoughby the dog is fooled by George the fox. Willoughby is voiced by Tex Avery, while George’s voice is done by Mel Blanc.
Now what does this have to do with Safety Data Sheets or SDS? Often when tasked with writing a SDS one can feel like poor Willoughby. All of the information is available, but which way do you go. Which way do you go?
ICC Compliance Center can help and it won’t be in the way of George in the cartoon. We offer five different SDS Services.
But how do I choose which is right for me?
- SDS Creation: The process is simple. Send us a basic product information sheet, the raw materials SDS documents, and the countries involved and we can write an SDS for you that meets the requirements of OSHA HazCom 2012, WHMIS, European REACH, or European CLP. We even offer to sign a non-disclosure agreement to keep your product information private.
- SDS Reformats and Revisions: Most companies already Continue Reading…
Remember eating alphabet soup as a child? Remember playing with the noodle letters to make more words than your friends or siblings? Remember when the letters would not cooperate and random letters were floating in your bowl? Remember trying to use abbreviations and acronyms to make those random letters work? Oh, the frustration! Working on Safety Data Sheet (SDS) documents in the European Union (EU) can often feel like some of those memories.
ICC Compliance Center is here to help and possibly give some new ways to win in your next competition.
EU – Directives and Regulations
As a reminder, the EU governs hazard communication in two ways – by directives and regulations. Directives mean all member states are required to implement their version of the directive within their state. Regulations, however, mean complete implementation in all member states without the need for or allowance of versions in each state.
Current directives and regulations
As of February 2015, there are multiple active directives and regulations at work in the EU. The oldest is the Dangerous Substances Directive (67/548/EEC) or the DSD and the Dangerous Preparations Directive (1999/45/EC) which is the DPD. This is followed by the Registration, Evaluation, Authorization and Restriction of Chemical Substances Regulation more commonly known as REACH (EC1907/2006). Finally, there is the Regulation on Classifying, Labeling and Packaging of Substances and Mixtures (1272/2008/EU) or in the shortened form the CLP. It should be mentioned Continue Reading…
Health Canada Reveals Final Version of Canadian GHS
An important change has occurred on the Canadian regulatory scene. Health Canada has released the long-awaited revisions to the Workplace Hazardous Materials Information System (WHMIS) for hazardous workplace chemicals. This new system will introduce sweeping changes for classification of chemicals, labelling of workplace chemicals, and Material Safety Data Sheets (which will now be known simply as Safety Data Sheets or SDSs).
The new system will replace the Controlled Product Regulations with the Hazardous Products Regulations. This new regulation will incorporate a system that has been adopted by the United States, Europe and many other countries and economic zones. Using this new system is anticipated to help Canada compete in international markets, as well as make importing workplace chemicals less complicated and expensive.
The text of the new regulation can be downloaded from Canada Gazette’s website (PDF). Compliance will not be mandatory right away – there will be a series of transition periods, leading to final adoption by December 1, 2018. However, you may start using the new system immediately if you prefer.
Also updated is the regulation for considering trade secrets, the Hazardous Materials Information Review Regulations.
More WHMIS 2015 Resources
ICC Compliance Center is currently studying these new regulations, and will keep all our customers up to date on the Continue Reading…
In the 1960’s, an American author by the name of Robert A. Heinlein wrote a science fiction story about a man born and raised on Mars, but as an adult comes to Earth. The title of the novel is “Stranger in a Strange Land”. The plot focuses on the main character adapting and understanding humans – their language, laws and culture.
How does this connect with ICC Compliance Center, Safety Data Sheets (SDS), and labels one might ask? Consider this scenario: a US chemical with its SDS and label end up in a Chinese chemical plant or a Romanian factory. Can the workers in either of those places read it? Can it be understood? Are the workers aware of the hazards or dangers of the chemical? Are these workers safe when using this US chemical?
By using ICC Compliance Center, companies now have the capability to translate an entire SDS or label into any of 40 languages. Granted using a third-party is a possibility for translating specific words and phrases, but that can be expensive given how long SDS documents and labels are under the new GHS regulations. ICC Compliance Center is different, because we allow for flexibility when translating. Since we work per SDS document we’re likely a lower cost than other companies.
One also has to remember the regulations and what they Continue Reading…
As of now we should all know or have at least heard that OSHA adopted the hazardous chemical labeling requirements in the latest revision of the Hazard Communication Standard. By aligning with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals or GHS, OSHA helps ensure uniformity in the labeling of chemicals. These updates will provide workers with better information on safe handling and usage of hazardous chemicals. Therefore, providing a systematic approach for avoidance and exposures to hazardous chemicals, reducing injuries and illness through worker awareness.
The upcoming June 1, 2015 effective date, manufacturers, importers and distributors can maintain compliance with the requirements of HazCom 1994 or the revised standard. However, manufacturers, importers, and distributors may start using the new labeling system in the revised Hazard Communication Standard (HCS) before the June 1, 2015 effective date. Hazardous chemicals shipped after June 1, 2015, are required to be labeled with the identified elements including pictograms, signal words, hazard statements and precautionary statements. Distributors have until December 1, 2015 to ship containers labeled by manufacturers or importers in compliance with the HazCom 1994, after which it is required to comply with the HazCom 2012.
According to the revised standard the required information regarding chemical hazards must be communicated on labels using visual cues for awareness to the users. Labels, defined in the HCS, are Continue Reading…
Help! I’m lost!
Here it is January of 2015 and I’m so lost and confused in this world of Hazard Communications. Is there a set of directions or a map through this land of labels, safety data sheets and classifications? Daily, phrases such as “UN Model Regulations”, “Purple Book”, “HazCom2012”, “GHS Classification” and “June 1, 2015” are tossed around in conversation with great emphasis.
Are these the same?
Are they different?
Can you explain it?
Luckily, ICC Compliance Center is here to help with you navigate. There are multiple resources in particular that can help.
Here is just a sample of what we have to offer:
Globally Harmonized System of Classification and Labeling of Chemicals (GHS)
Also known as the “Purple Book”: This is the UN Model REGULATION that outlines exactly what GHS is. It explains the comprehensive changes to how customers are informed of hazards, by finally establishing an internationally uniform system for classifying hazardous chemicals, labeling them and providing Safety Data Sheets (SDS). Encompassing many sectors, including workplace safety, consumer sales, transportation, and environmental protection. This is updated every two years so be sure to use the correct edition! Use this to see if you are on the correct continent of your map.
Just HazCom: Hazard Communication Regulation
Here is “HazCom2012” or the “US GHS”. “Just HazCom” has the parts of 29 CFR 1910.1200 used to ensure that the hazards of all chemicals produced Continue Reading…
Nola Murphy’s Story
It was in a soft-drink bottle. It looked like lemonade. But 73-year-old Nola Murphy discovered, after pouring herself a glass, that it wasn’t. In fact, it was a toxic mould-remover that a cleaner had left sitting on a restaurant bar. The cleaner had poured the product from a larger container into the soft drink bottle for easier handling.
Mrs. Murphy was lucky – she survived the experience, although she required emergency hospital treatment. But her story, given in an article in the New Zealand Medical Journal, shows how putting hazardous chemicals in unlabeled containers can be a recipe for disaster. (More: The New Zealand Herald)
Many countries, including the United States and Canada, require hazardous chemicals sold to the workplace to be labeled by the supplier. Regulations such as the U.S. Occupational Safety and Health Act (OSHA), and Canada’s WHMIS (Workplace Hazardous Materials Information System), set out the basic requirements for such labels (called “supplier labels” under WHMIS, and “labels for shipped containers” by OSHA). But as Mrs. Murphy’s experience shows, many hazardous chemicals still end up in unlabeled containers. They may be poured (“decanted”) from larger containers for convenience. The original supplier label may have been damaged or removed. Or two or more chemicals in separate containers may be mixed together to make a new product. No matter how it happens, unlabeled chemicals create a Continue Reading…
Hazcom 2012 Deadline Extensions Denied
In August 2014, nine industry organizations filed a formal request to OSHA (Occupational Safety and Health Administration) asking to extend the deadline for compliance with the new hazard communication requirements for two years. The new requirements were published as a Final Rule on March 26, 2012 and became effective May 25, 2012. This rulemaking is based on the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and is referred to as Hazcom 2012.
Chemical manufactures and importers have until June 1, 2015 to be fully compliant with the new labeling and SDS requirements. While industry has been supportive of the new requirements put in place by OSHA, compliance has been a very slow and difficult process. The petition for delayed compliance with Hazcom 2012 was filed due to the lack of updated classifications available down the supply chain to end users. Many manufacturers are concerned that they will not be able to accurately classify their products by the June 1 deadline due to incomplete information for raw materials that is currently available.
Recently, OSHA responded to the requesting organizations, denying the extension of the deadline. OSHA states that while they understand the scale of the changes required in the new standard, they feel that the June 1 deadline is still reasonable. OSHA plans to use discretion in enforcement to address the Continue Reading…
10 disharmonies within Revision 5, HazCom2012, and Canada’s proposed WHMIS 2.0.
The more we work under the Globally Harmonized System for Classification and Labeling (GHS) the more we find disharmony among countries and its adoption. Between Revision 5 of the GHS, US HazCom2012 and Canada’s proposed WHMIS 2.0, there are 10 areas where things just do not connect or show disharmony. When more countries are included the number of disharmonies grows exponentially. By now the alarm bells start to ring – LOUDLY.
At the bottom of this article, you will find a PDF download that illustrates this disharmony on a global scale.
Whether you are working on a classification, a label or just gathering information, being aware of how these disharmonies impact how the work is done is imperative.
So under Physical Hazards there are 3 areas of disharmony. Ding!
- Explosives: In Revision 5 and in US HazCom2012 there are six divisions including one for unstable explosives. The criteria match completely. Disharmony alarms ring when you look at Canada’s proposed WHMIS 2.0. Under this proposal, there are no criteria. Classification occurs under the Canadian Explosives Act
- Chemically Unstable Flammable Gases: Revision 5 has Categories A and B while HazCom 2012 and Canada’s WHMIS 2.0 did not adopt the criteria for these and as such do not address Chemically Unstable Flammable Gases
- Flammable Aerosols: Here Revision 5 has Categories 1, 2 and 3, but the US and Canada Continue Reading…