As part of the United States’ federal adoption of the internationally-recognized system of chemical labelling and communicating usage data related to chemicals, known as the Globally Harmonized System (GHS), the U.S. government has begun to phase in small steps to help ensure workers have the necessary training as the GHS transition rolls out.
Although the GHS will not be fully implemented until 2016, there is already a U.S. Occupational Safety and Health Administration (OSHA) 2013 deadline that employers must be aware of: by December 1, 2013 employers must have trained employees about the new GHS Safety data Sheet (SDS) format and label elements.
In other words, employees must be able to read and use GHS-style SDSs and GHS labels before the new labels are formally rolled out in workplaces across the U.S.
Many employers have already begun the new training process, and some have even taken the advanced step of implementing the GHS-style SDS in their facilities.
What Type of Training is Necessary?
OSHA requires that employees are giving all the information they need to safely use chemicals and react appropriately to chemical hazards. This means that employees need to be able to read GHS SDSs, particularly the new GHS elements that differentiate the GHS-style from the common MSDS.
- How to read Product Identifiers: the way that hazardous chemicals are named, coded, or numbered by batch on the label.
- Understanding Signal Words on SDSs, which are used to indicate the level of hazard associated with the chemical. In the U.S. only two signal words are in use – “Danger” for more severe hazards and “Warning” for less severe hazards.
- Learning what each GHS Pictogram means: the OSHA-adopted GHS label includes several pictograms that immediately signal specific hazard categories. Employees should be able to know which pictograms indicate which dangers. Note that many of the GHS pictogram overlap with MSDS pictograms, so employees are likely to already know most pictograms’ meanings.
- Understanding Hazard Statements, which are used to describe the type of hazard an employee should be aware of (for example, “causes eye irritation” or “fatal if swallowed”). Again, these hazard statements are similar or identical between GHS- and MSDS-style SDSs.
- Learning how to use Precautionary Statements. These are statements that describe the recommended measures that should be taken to minimize or prevent adverse effects through the use of the chemical(s) in question.
- Where to find the contact information of the chemical manufacturer, distributor, or importer.
OSHA also expects employers to train employees on how they might encounter and use the new GHS SDSs in their own workplace. Some examples of this include:
- How the GHS SDS tells users how to properly store chemicals.
- How the GHS SDS tells users how to respond in a first-aid scenario.
- Showing how the different parts of the GHS label work together (i.e. pictograms match up with hazard statements).
- Explaining that when a chemical has multiple precautions the label will include the most effective protection method.
Finally, OSHA has also stated that all GHS training must include information about each of the 16 standardized sections of the GHS SDS and how the GHS SDS and GHS label are related.
It is also necessary to keep in mind that OSHA regulations state that employers must present this type of training in a manner and language that employees are able to understand. Consequently, if you have employees that regularly communicate in a language other than English in your facility, you are expected to provide GHS training and materials in the appropriate language. In a similar vein, employees with visual or hearing disabilities need training to be delivered appropriately, and employees unable to read GHS training materials cannot be covered by only being given written training documents.
Help Getting Started
OSHA has provided some materials to assist employers begin this mandatory training. These online documents, provided in English and Spanish, include sample labels and reference materials that should be used during your training.
Hazard Communication Standard Label Sample [pdf]
Hazard Communication Standard Pictograms [pdf]
Hazard Communication Safety Data Sheet Sections Summary (English Only) [pdf]
Safety Data Sheet Sections in Detail (English Only) [pdf]
In addition, here are some helpful articles from ERA for manufacturers and other businesses looking to learn more details about the switch to GHS, including: how it will have an impact on your business, why OSHA feels the change is necessary, and what the major changes are with the GHS-style of chemical labelling. Want advice on how to set up a successful SDS Management System? Our eBook details the necessary steps to ensure your SDS Management System is GHS compliant.
Or learn about the business risks and opportunities of the GHS transition here:
July 23, 2013