As health and safety professionals strive to comply with the requirements if the Globally Harmonized System elements of the most recent version of OSHA 29CFR1910.1200 (Hazard Communication), they are discovering that the new standards are involving and have changed the nature of compliance documentation efforts.

For example, the 6th revision to the United Nations Globally Harmonized System has been adopted. How will these changes impact the workplace? While updating the Safety Data Sheet documents, preparers made the perplexing discovery that the same chemical can have a wide variation in hazard classification, based on the information manufacturers and importers are currently reporting. How can this development be adequately addressed in compliance procedures? Employers are striving to determine how to translate GHS pictograms and hazard classifications into sensible workplace labeling options. What are options that can work well for their specific facilities? Finally, those in charge of documentation are now trying to anticipate what will happen next, in terms of hazard communication requirements. How can they prepare?

Overview of Compliance Concepts

The successful approach to implement the standard is focusing on the employee's "right to understand" The four elements in this reaching this objective is are as follows:

  • Hazard Classification: Resources that are readily available and user-friendly, as well as strategies to obtain the information required to assess Hazard Classes and Hazard Categories.

  • Labels Creation: Beyond the basic elements that are required in HCS 2012, different products may have strict space limitations or utilize DOT labels. In-House/Workplace labels must be able to convey hazard class information and composition to employees who have been trained to understand systems used.

  • Safety Data Sheet: There are specific sections required under HCS 2012, and elements that must be present in several of these sections. SDS Collections must be readily available to employees, and employees must be trained to use the HCS 2012 compliance documentation to make the proper choices in personal protective equipment, engineering controls, work practices, or emergency response procedures.

  • Future of GHS/HCS Compliance: The GHS requirements are regularly updated and the federal rules will likely be amended more frequently going forward. Additionally, updated exposure limits, new test data, and revised chemical hazard assessments may impact Hazard Class/Hazard Category, labels, and Safety Data Sheet information. Compliance programs must be prepared to deal with more regular changes.

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