by Ana Ellington, Legal Editor

In May 2012, the Occupational Safety and Health Administration (OSHA) revised the hazard communication standard (HazCom 2012) to align with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

One of the GHS requirements is that chemical manufacturers and importers must provide a label on all shipped hazardous chemical containers that include a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.

HazCom 2012 includes the following additional major requirements:

• Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
• Safety Data Sheets (SDS): The new standardized format requires 16 specific sections, ensuring consistency in the presentation of important protection information.
• Information and training: To simplify the understanding of the new system, the new standard required that all employers train their workers by December 1, 2013, on the new label elements and standardized safety data sheet (SDS) format, in addition to the current training requirements.

These significant changes that impact employers as well as chemical manufacturers, importers, and distributors will be phased in through June 1, 2016. By June 1, 2015, chemical manufacturers and importers must comply with all the requirements of the HazCom 2012 (e.g., hazard classification, GHS-compliant label and the SDS), except compliance with the GHS label requirements is optional for distributors until December 1, 2015. By that date, all shipments of chemical containers must include the GHS-compliant label.

The final phase-in date is June 1, 2016, by when employers must update alternative/secondary workplace labeling and their hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

What is GHS?

The GHS is a system for standardizing how chemicals are labeled and classified across the globe. It provides a standardized way to determine how hazardous chemicals can affect health and safety. The GHS is intended to improve understanding of hazards and lead to better handling and use of chemicals in the workplace.

Required GHS label elements

The labels provide workers immediate visual reminders of hazards. The elements of a GHS-compliant label include:

• Product Identifiers: Chemical name, code, quantity, etc.
• Supplier Information: Manufacturer’s company name and contact information.
• Pictograms: Nine different black symbols with a diamond-shaped red border that depict the hazard classification of the given chemical.
• Hazard Statements: Various detailed phrases describing the hazards associated with a chemical, e.g., flammable gas, fatal if swallowed, causes eye irritation.
• Precautionary Statements: Four types of precautionary statements must be on each label: prevention, response, storage, and disposal.
• Signal Word: One of two signal words for alerting the level of hazard on each label:
• DANGER—more severe hazards possible.
• WARNING—less serious hazard.
• Supplemental Information: Any other instructional information that the chemical manufacturer would like to provide.

GHS-compliant label

Pictograms

The nine pictograms used are designed for quick recognition and conform to what other GHS users across the world expect to see. Even though the GHS uses nine pictograms, OSHA enforces for eight, since the environmental hazard pictogram represents the kind of hazard that the U.S. Environmental Protection Agency enforces.

These pictograms do not replace the diamond-shaped labels required by the U.S. Department of Transportation (DOT), which go on chemical drums, totes, tanks, and other containers for transport.

What about NFPA and HMIS labels?

If your secondary or workplace containers have National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) labels on them, you will not need to peel off the old labels; they are useful for first responders and those planning for emergency response. But they are no longer in compliance with GHS labeling—informing workers about the hazards of chemicals. When HazCom 2012 is fully implemented, it will still be okay to have NFPA and HMIS labels as long as they are consistent with the GHS labeling system or you could also have GHS labels on the same containers.

Like the NFPA, the GHS standard assigns numerical ranking to hazard levels. However, the two systems are the opposite: NFPA ranks 1 as the lowest hazard level, and GHS ranks 1 as the highest. This conflicting approach does not affect labeling, as the hazard ranking by number does not appear on a GHS-compliant label. However, the difference could cause confusion when reading the SDS or attempting to create labels without proper training.

What about training?

Along with labels on containers and SDSs, employee training is one of the core components of a comprehensive hazard communication program. Remember that under HazCom 2012, your employees not only have the right to know but also the right to understand the chemicals in the workplace and how to handle them safely. Training is needed to explain and reinforce the information presented in the SDSs and on the chemical container labels to ensure that your employees understand the chemical hazards in their workplace and are aware of the protective measures they need to follow.

To ensure employee understanding is effective, train on old labels and the GHS-compliant label formats as long as you have the older labels on your workplace containers.

If you decide to use alternative workplace labels and the GHS-compliant label, you will need to train your employees on both. In other words, employees must not lose any protections they have under HazCom 2012.

A best practice is to label your secondary container chemicals with the same GHS label information that came on the shipped container label—or the primary label.