Recently we wrote about how the new GHS (Globally Harmonized System) standards for safety data sheets (SDSs) differ from the typical OSHA-style MSDSs that can be found any U.S. workplace that uses chemicals. Although a lot of the information between the two standards overlap, chemical manufacturers will still see an increase the amount of work they need to do to create GHS-compliant labels and SDSs.
It’s important to remember that U.S. chemical manufacturers are not yet required to comply with the GHS standards, although the Occupational Health and Safety Administration has committed to making the switch in the near future - 2015. What that means for your business is that it’s time to start getting ready now.
To help you get ready to make the switch, this article will explain OSHA’s reasoning for why adopting the GHS is a good move, and what you can expect in terms of cost and changes during the shift.
Why Make the Switch?
OSHA has predicted many benefits will come from making the switch to GHS, largely based on examples of the benefits that many other GHS users are already experiencing (particularly in the European Union). Although OSHA is primarily concerned with workplace safety, they have taken into account that businesses must be better off as well - the decision to commit to GHS includes a handful of time and cost saving benefits.
Because the GHS’s top priority is getting safety information to workers as effectively as possible, the number one expected benefit is that every industry that uses any type of chemical will see a dramatic decrease in workplace injuries, spills, and sick days. The side effect of this will be an increase in workplace productivity and less money lost to sick pay. In more extreme cases, it could prevent many serious injuries and paying out workers compensation. The decrease in sick days and injuries, and the associated costs, will vary by the type of chemicals you manufacture or use.
A secondary benefit of the new GHS SDSs will be that EH&S managers will need to spend less time filling out lengthy injury reports or dealing with things like spills. As we’ve written about before, any project or initiative that saves an EH&S manager time (which is one of his or her scarcest resources) is good for business. This is especially true if you have just one manager in charge of environmental compliance, workplace safety, and employee health; there’s rarely enough time to do the basics of all three, let alone lead a cost-saving sustainability program.
If your business operates on an international scale, or you export products or chemicals overseas, you’ll benefit from the fact that chemical labeling practices will be the same from country to country. That means you won’t need to worry about your labels being compliant in one region and not in another. It means you have easier access to a more global market. It also means you’ll communicate chemical data between facilities using the same “language” even if you aren’t technically speaking the same language.
The Cost of Implementation
Even though OSHA expects some significant benefits for both workers and businesses, there will definitely be some changes in the future which some companies (particularly chemical manufacturers) will find burdensome in the short term.
The biggest challenge will be for chemical manufacturers to go through the process of updating all their current and future labels and SDSs. This means collecting a potentially huge amount of new information about your products that isn’t typically contained in your standard OSHA MSDS. Depending on how thorough your own internal testing and recordkeeping is you may already have all or most of the data you’ll need. If not, you’ll need to collect the new data required by the GHS, including:
- Decomposition temperature
- Toxicity info
- Aquatic and terrestrial ecotoxicity
- Bioaccumulative potential and mobility in soil
- Safe disposal methods
- United Nations number and proper shipping name
- A list of regulations related to the use of the substance, both local and global
- Unsuitable fire-fighting methods
- The four essential elements of a GHS label: signal word, hazard and precautionary statements, and pictograms. (Learn all about them here).
In addition to revising labels and SDSs, chemical manufacturers will also need to ensure their substances are correctly classified under the new GHS hazard classes and categories. This could require additional testing.
In addition to all the new data you’ll need to capture, OSHA has proposed changes to workplace safety training that will require businesses to teach employees about the differences between the GHS and the OSHA standards. This means revisiting your current training program and updating manuals. While this requirement doesn’t pose a huge time or money cost, it will impact productivity for a short period.
Overall, the biggest challenge will be the adjustment period that workers, manufacturers, and business owners will need to go through. If not properly managed and prepared for, the switch to GHS could cause some on-site confusion, delays in getting products labelled correctly, and possibly a momentary spike in worker injuries or spills. That’s why it’s essential to prepare as soon as possible for the new standard to avoid these types of setbacks - OSHA will need you to start by te end of 2013.
How to Prepare
Luckily, preparing for the GHS is not difficult. In fact, it’s all about getting your chemical data in order and getting familiar with the GHS standards. You can find a free copy of these standards – known as the “GHS Purple Book” –online from many different sources, including online here.
One of the best ways of prepping is to get your own internal data collection practices standardized and all in one place. That will make it significantly easier to find the chemical data you’ll want for the new labels. It’s also a great idea to start calculating and testing for all the mew metrics you’ll be asked to provide. Finally, we recommend creating an electronic library of all applicable regulations. We explain the process of doing that briefly in our guest article on Environmental Leader.
December 20, 2012