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October 27, 2016
Hazard communication: SDS and secondary label compliance following the GHS deadline

By Melissa McCaffrey

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While OSHA’s final compliance deadline for its alignment of the Hazard Communication Standard (HazCom) with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) began in March of 2012 and concluded in June 2016, many employers are still plagued with lingering questions and concerns, and still working toward transitioning their workplaces. Two common areas of concern have been what to do about managing safety data sheets (SDSs) and workplace labels.

Under OSHA’s HazCom Standard, it’s the employers’ responsibility to ensure use of the most current SDSs for hazardous chemicals in their inventories. It had been OSHA’s expectation that by now, employers’ inventories would be fully transitioned to include only GHS-aligned SDSs.  Unfortunately, that’s just not the case. Both manufacturers and distributors were delayed in meeting their own GHS deadlines, resulting in downstream users—i.e., employers—having inventories that still contain older-formatted material safety data sheets (MSDSs).

The co-existence of both document types complicates things on several fronts. First, it requires employers to continue training on both document types, something OSHA says must be done as long as both document versions exist in an employers’ inventory. Secondly, it draws increased scrutiny from inspectors who expect to see an inventory of fully GHS-aligned SDSs. If inspectors come across MSDSs, they may question why the documents haven’t been updated to the SDS format. Employers should be prepared to provide proof of their product delivery timeframes, and documentation of their attempts to retrieve updated SDSs for any product shipments that arrived after the June 1, 2015 manufacturer and December 1, 2015 distributor deadlines.

Since chemical manufacturers and distributors are only required to send along GHS-aligned SDSs for a chemical with a first shipment or the next shipment following an update to the document—or at the request of a downstream user—the state of employers’ inventories may remain in flux indefinitely, until or unless proactive measures are taken to retrieve updated SDSs.  To protect themselves from citations, employers should keep a record of all communication with suppliers, including any calls, emails and letters demonstrating their attempts to retrieve the required SDSs.

Plenty of variables can inhibit employers’ ability to fully transition to an SDS-only library, and when it comes to addressing workplace labels (also called secondary or in-plant container labels), the issue of variability takes new shape. The OSHA requirement for workplace label compliance remains performance based; the Agency offers three ways to comply and will use the GHS-aligned manufacturer shipped label as a benchmark for determining how well a label performs.

The first option is for employers to replicate the product’s GHS-aligned manufacturer shipped label (which includes a product identifier, signal word, hazard statement(s), precautionary statement(s), pictograms and supplier information). The second option is to use a product identifier, plus some combination (but OSHA doesn’t specify which) of words, pictures, and/or symbols, which in conjunction with other information immediately available in the workplace under the HazCom Program successfully communicates to employees all of the specific hazards associated with a chemical. The third option is to use an existing label that was compliant under the pre-GHS HazCom Standard, so long as it includes a product identifier and is able to successfully communicate all of the hazards of a chemical.

Replicating the shipped label would be considered a best practice since it provides greater consistency between shipped labels and those found in the workplace. An inherent benefit is that employees should already be trained on the GHS-aligned manufacturer shipped label format, so it eliminates the need for additional training on a separate label system and lessens the burden placed an alternative label to perform as effectively as the shipped label. Furthermore, a good electronic chemical management system can help you easily produce GHS-aligned workplace labels using information taken directly from a product’s SDS.

GHS alignment is now the law of the land for HazCom, so it’s critical that employers address any questions or confusion they still have around the GHS-related changes, and that they get their SDS management and workplace label processes in order. OSHA inspectors will be looking for employers to have fully transitioned HazCom Programs in place, including updated SDS libraries and alternative workplace label systems that communicate all hazards associated with a hazardous chemical.

What’s more, OSHA has stated its intent to modify the rule in the future as needed to maintain alignment with newer versions of the GHS as formulated by the United Nations. It’s important to not view the conclusion of the GHS deadlines as the end of the process, but instead as a giant first step that gets us closer to what may be the smaller but still significant GHS-related changes to come.

 

Melissa McCaffrey is an EHS content editor and director atVelocityEHS, a leading cloud EHS software company dedicated to helping its customers reach their EHS and sustainability goals faster through a simple and intuitive platform that is more affordable and faster to implement. The company’s MSDSonline chemical management solutions help companies better understand their chemical risks, simplify compliance requirements and safeguard employees. For more information visit www.EHS.com or call 1.888.362.2007.  

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