GHS Transition Tips…in Case You’ve Been Procrastinating

The transition from OSHA’s old Hazard Communication Standard (HCS) to the new standard that incorporates the United Nations’ Globally Harmonized System (GHS) is well underway, as employers were required to train their employees on the changes to chemical labels and safety data sheets (SDSs) by December 1 of last year.

OSHA wanted the end users of chemicals to understand the new sheets and labels before the implementation of changes to avoid possible confusion. (So if you haven’t done any training yet, it’s time to start!)

Maybe your facility already completed the required training and you have a plan for moving forward with the transition. If so, that’s great. If the plan for dealing with the GHS changes is a little murky at your facility, though, we’d like to offer some information and tips to help you move forward as painlessly as possible.

GHS Transition Timeline

First things first, let’s look at the upcoming deadlines. They may sound like they’re a long way off yet, but they’ll be here before you know it, especially if you don’t do some prep work now.

June 1, 2015: Chemical manufacturers, importers, distributors and employers must all comply with OSHA’s modifications to the HCS. The exception: Distributors can continue to ship chemicals with the old system’s labels.

December 1, 2015: Distributors must ship only chemicals labeled with new GHS labels.

June 1, 2016: Employers must update labeling and their hazard communication program as necessary and provide training when new hazards are identified. 

These deadlines give employers a little less than a year to get a compliant program up and running, so it’s important to take steps now. Not all of the required changes can be done overnight.

What’s Changing?

You may already know that the GHS changes have to do with hazard classification, container labels and safety data sheets for hazardous chemicals. The changes are quite detailed, though, and are worth a close examination. In general, requirements under the new HCS are more specific than those of the old system.

Hazard Classification

OSHA has changed the definitions for hazards, and now specific criteria are provided to determine whether a chemical (or a chemical mixture) is a health or physical hazard. Under the new system, each class of hazards is divided into categories that indicate the severity of the hazard.

Labels

Chemical manufacturers and importers will need to include a label that follows the new GHS format, and employers will need to make sure any other containers that eventually hold these chemicals have the same label. The new labels incorporate product identifiers (names), pictograms, signal words (“Danger” or “Warning”), hazard statements, precautionary statements and supplier information.

In the past, employers were given some flexibility with chemical labeling, but GHS requirements standardize labels so that they will be easily understood and provide specific, detailed information.

In the image below, you can see the six parts of the label:

• The product identifier tells us the chemical is ammonia.
• The signal word tells us the level of hazard (“Danger,” which is more severe than “Warning”).
• The hazard pictograms, which are always shown in red diamonds and contain one of nine images, tell us ammonia is toxic, corrosive and a gas under pressure. The symbol with the tree and the fish indicates ammonia is an environmental hazard, but OSHA does not require this type of labeling because it is outside of its jurisdiction. (For explanations of all of the pictograms, see this guide).
• The hazard statement explains that ammonia can cause severe burns and be fatal if inhaled. It also provides first aid instructions.
• The precautionary statement includes information for storage.
• The supplier information section includes pertinent contact information.

Safety Data Sheets

“Safety Data Sheet” itself is actually a new term, and it replaces the old Material Safety Data Sheet (MSDS). These two documents are not incredibly different, but the new standard does require a more specific order of information. In the past, MSDSs contained between eight and 16 sections, and required information just needed to be present on the documents. New SDSs have 16 sections and the information must be listed in a specific order to make it easier for people to find what they need to know quickly. OSHA will technically not regulate sections 12 through 16 of the SDS because that information doesn’t fall under their jurisdiction (it relates to the environment, disposal of waste and transportation).

The 16 required sections are:

Section 1 – Identification

Section 2 – Hazard(s) identification

Section 3 – Composition/Information on ingredients

Section 4 – First aid measures

Section 5 – Fire-fighting measures

Section 6 – Accidental release measures

Section 7 – Handling and storage

Section 8 – Exposure controls/Personal protection

Section 9 – Physical and chemical properties

Section 10 – Stability and reactivity

Section 11 – Toxicological information

Section 12 – Ecological information

Section 13 – Disposal considerations

Section 14 – Transport information

Section 15 – Regulatory information

Section 16 – Other information, including date of preparation or last revision

By now, employees should be trained in how to recognize and read the new GHS labels and SDSs, so if you haven’t already gone over these new standards with your employees, you must do so.

Tips for Dealing with GHS Changes

Understanding the changes is just the first step to transitioning to the new GHS standard. You need to put someone in charge of the process at your company, make sure everyone is on the same page and update lots of documentation and labels. Here are a few tips for starting the process:

• Train. Make sure everyone can read the new labels and SDSs. Take extra time to make sure the people who will be receiving or logging shipments and moving chemicals in your workplace understand this information. Then those individuals can alert the person in charge of updating SDSs if necessary.
• Update MSDSs. Over a fairly short period of time, an employer’s MSDSs will all be replaced with new SDSs from chemical manufacturers. Come up with a plan for making sure your MSDSs all get updated. An electronic system for storing SDSs can make the process a lot simpler than using paper.
• Consult Vendors. If possible, discuss the process with your vendors. When do they plan to change the documents? Knowing this information ahead of time can make your transition smoother.
• Make a Plan for New Labels. While it may be possible to adapt an old label to meet GHS guidelines, it’s likely getting new labels will be easier. You can either purchase the labels from a vendor or print them yourself using an industrial label printer. Check your chemical inventory to see what labels you’ll need to make.

Feel like you have GHS labeling and SDSs under control? Take this quiz to test your knowledge. If you’re still feeling confused about the differences between the old system and the new one, OSHA offers a side-by-side comparison of the two.

Additional Resources

• GHS Label Creation– creativesafetysupply.com
• GHS Safety Data Sheets (SDS)– realsafety.org
• Creating A GHS Compliant Label– industriallabelprinters.net
• Chemical Hazard Labels: Do Yours Look Like this Yet?– creativesafetypublishing.com
• New Changes in GHS Revision 8 (Published 2019)– blog.creativesafetysupply.com
• GHS labels: What you need to know– hiplogic.com
• A Guide to GHS Labels– iecieeechallenge.org
• A Guide to GHS Pictograms– babelplex.com
• Pipe Marking in the Warehouse – 5 Tips– warehousepipemarking.com