Final GHS Deadline – But Many Companies Continue to Work Towards Achieving Compliance

By June 1st, all employers were to update alternative workplace labeling to GHS compliant labels on all chemicals in storage, update their Hazardous Communication (HazCom) programs and re-train employees to understand GHS pictograms and hazard warnings.  However, if your program is not 100% compliant yet, you are not alone. According to a recent study conducted by Actio Software Corp., roughly 50 percent of environmental, health and safety (EHS) professionals surveyed indicated that their company fails to meet all of the GHS requirements outlined under OSHA’s revised Hazard Communication Standard (HCS) in 2012. Out of the 50 percent of participants who claimed their company was not yet GHS compliant, 48 percent estimate that it will take their company at least another 120 days to complete OSHA’s HCS obligations.

What is the major obstacle preventing GHS Compliance? Not surprisingly, companies identified the ability to obtain updated Safety Data Sheets (SDS) as the biggest challenge associated with making the GHS transition. However, with HazCom being the second most frequently cited violation by OSHA for non-compliance, there is no “excuse” or any “safety in numbers” inherent in being part of the many struggling to meet the HazCom/GHS requirements.

So, if you find yourself still in the non-compliant group, the following best practices, as first published in EHS Today, can help your company obtain and maintain GHS compliance:

  • Conduct regular chemical inventories: By performing a chemical inventory, your staff will be able to verify that they have the most recent SDS available for all of your hazardous chemicals. Regardless of whether or not the SDS is in the GHS format, having the most current information will improve worker safety and make it easier to track and maintain your SDS library.
  • Establish consistent communication with suppliers: Employers are responsible for making sure that their employees have access to the most updated SDSs. With this in mind, employers receiving non-GHS-compliant SDSs from suppliers should get in touch with their vendors to request GHS-compliant SDSs. If for whatever reason, the vendor is unable to supply the correct format, the employer should be sure to document their efforts to obtain the updated SDS.
  • Help employees transition from awareness to understanding: As part of a compliant HazCom program, employers need to train employees on any newly discovered hazards listed on safety data sheets and labels so that they are aware of dangers and know what procedures to follow if contact is made. Employers should host regular training sessions that focus on helping employees gain a solid understanding of the elements found on GHS labels and SDSs including, but not limited to, signal words, pictograms and first aid measures.
  • Keep an eye out for updated SDSs: Making sure employees are trained on the new GHS formats will help them quickly identify updated SDSs. As new SDSs enter the facility, trained employees will be able to spot GHS SDSs and use them to update binders and create secondary container labels to ensure that your company remains compliant with OSHA’s HCS.
  • Leverage technology: There are many affordable SaSS and cloud-based EHS software solutions on the market today that can help manage your company’s GHS responsibilities.

Published by Stephen Kovatch

Senior Client Manager  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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