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Time to Comply with the Globally Harmonized System for Safety Data Sheets Download OSHA Hazard Communication Pictograms to comply with new SDS requirements. Summary After years of controversy, a Globally Harmonized System for labeling safety information on chemical containers has finally been created. In 2012, OSHA published its variation, the OSHA Hazard Communication Standard (HCS). Full compliance by U.S. employers, including steel erection contractors, begins June 1, 2016. Consider a container of chemicals entering a U.S. port, but we can’t read the label and we have no idea what’s in the container. Is it safe to open? What are the physical and health hazards? The United Nations recognized this import/export dilemma. Now every country that exports into a United Nations country must use the same labeling system and provide a Safety Data Sheet (SDS) with universally formatted information. Global harmonization was intended to protect human health and the environment, provide a framework for countries without an existing system, reduce the need for testing and evaluation of chemicals, and facilitate trade. The new OSHA Hazard Communication Standard (HCS), published in 2012, is aligned with GHS and its classification and labeling of chemicals in the United States. OSHA established a transition period for contractors to ensure employers would be in compliance. December 1, 2013 – All employees who use, handle, or store chemicals needed to ben trained in the new label system and safety data sheet (SDS) format. June 1, 2015 – All chemical manufacturers, importers, and distributors must be in compliance with the 2012 OSHA HCS requirements. This includes classification of chemicals, preparation of safety data sheets, and preparing GHS labels. December 1, 2015 – The grace period ended for shipping existing inventory that had older labels. All shipments of chemicals must have the new GHS compliant labels. June 1, 2016 – All employers must be in full compliance with the new HCS. This includes having updated their written workplace hazard communication program to incorporate the new GHS requirements and to have provided training to employees on their new workplace hazard communication program. Best Practices How does this effect the steel erection industry? Some of the chemicals steel erectors might have on their job sites include Oxygen, acetylene, welding rods, and grinding discs. As of June 1, 2016, employers should have completed all of the required steps to be in compliance with the standard. OSHA listed the six steps needed for full compliance in an OSHA FactSheet. 1. Learn the standard and identify responsible staff Have you designated a person who is responsible for your companies Hazard Communication program? Responsibilities and implementation should be assigned to a specific person. 2. Prepare and implement a written hazard communication program Have you updated your policy to meet GHS requirements and have all workplaces been provided with a written hazard communication plan? This is intended to be site specific and it is required to be readily available to your employees. A six-inch thick, 3-ring binder full of your old Material Safety Data Sheets (MSDS) listing chemicals you won’t ever have on your site doesn’t cut it. Information must be site specific. 3. Ensure Containers Are Labeled Have you ensured that that labels on shipped containers remain in place? I a label is damaged or missing, what is your company policy/process for replacing that label? Are you labeling other workplace containers where required? No you can’t use the coffee can or the soda bottle. Nice try. 4. Replace MSDS with SDS Next, make sure you have replaced all of your Material Safety Data Sheets (MSDS) with new Safety Data Sheets (SDS). The SDS is better formatted and contains more complete information. 5. Inform and Train Employees Have you trained your employees in the GHS labeling system and what and where the SDSs for your site are located? Have you ensured that your employees are trained and understand the updated company policy and procedures? 6. Evaluate Your Program The standard requires that you review our company policy, and update as needed, before June 1, 2016. After that, periodic review is required to ensure ongoing compliance. This means making updates to your SDS any time new chemicals are introduced to the work place and when there are changes in the work place and/or procedures. Help educate others and prevent injuries This Safety Flash was contributed by Troy Clark, President, MSC Safety Solutions in cooperation with SEAA’s Safety Committee. It is designed to keep members informed about ongoing safety issues and to provide suggestions for reducing risk. Best practices are gathered from a variety of sources. They may be more or less stringent than individual corporate policies, and are not intended to be an official recommendation from SEAA. Always get approval and direction from your company officers on any new practice or procedure as these best practices may not work for all situations. Everyone benefits when a worker avoids injury. Submit your ideas for Safety Flash with the Near Miss/Incident Investigation Report form. Submit to executivedirector@seaa.net.
Time to Comply with the Globally Harmonized System for Safety Data Sheets
Summary After years of controversy, a Globally Harmonized System for labeling safety information on chemical containers has finally been created. In 2012, OSHA published its variation, the OSHA Hazard Communication Standard (HCS). Full compliance by U.S. employers, including steel erection contractors, begins June 1, 2016. Consider a container of chemicals entering a U.S. port, but we can’t read the label and we have no idea what’s in the container. Is it safe to open? What are the physical and health hazards? The United Nations recognized this import/export dilemma. Now every country that exports into a United Nations country must use the same labeling system and provide a Safety Data Sheet (SDS) with universally formatted information. Global harmonization was intended to protect human health and the environment, provide a framework for countries without an existing system, reduce the need for testing and evaluation of chemicals, and facilitate trade. The new OSHA Hazard Communication Standard (HCS), published in 2012, is aligned with GHS and its classification and labeling of chemicals in the United States. OSHA established a transition period for contractors to ensure employers would be in compliance.
Best Practices How does this effect the steel erection industry? Some of the chemicals steel erectors might have on their job sites include Oxygen, acetylene, welding rods, and grinding discs. As of June 1, 2016, employers should have completed all of the required steps to be in compliance with the standard. OSHA listed the six steps needed for full compliance in an OSHA FactSheet. 1. Learn the standard and identify responsible staff Have you designated a person who is responsible for your companies Hazard Communication program? Responsibilities and implementation should be assigned to a specific person. 2. Prepare and implement a written hazard communication program Have you updated your policy to meet GHS requirements and have all workplaces been provided with a written hazard communication plan? This is intended to be site specific and it is required to be readily available to your employees. A six-inch thick, 3-ring binder full of your old Material Safety Data Sheets (MSDS) listing chemicals you won’t ever have on your site doesn’t cut it. Information must be site specific. 3. Ensure Containers Are Labeled Have you ensured that that labels on shipped containers remain in place? I a label is damaged or missing, what is your company policy/process for replacing that label? Are you labeling other workplace containers where required? No you can’t use the coffee can or the soda bottle. Nice try. 4. Replace MSDS with SDS Next, make sure you have replaced all of your Material Safety Data Sheets (MSDS) with new Safety Data Sheets (SDS). The SDS is better formatted and contains more complete information. 5. Inform and Train Employees Have you trained your employees in the GHS labeling system and what and where the SDSs for your site are located? Have you ensured that your employees are trained and understand the updated company policy and procedures? 6. Evaluate Your Program The standard requires that you review our company policy, and update as needed, before June 1, 2016. After that, periodic review is required to ensure ongoing compliance. This means making updates to your SDS any time new chemicals are introduced to the work place and when there are changes in the work place and/or procedures. Help educate others and prevent injuries This Safety Flash was contributed by Troy Clark, President, MSC Safety Solutions in cooperation with SEAA’s Safety Committee. It is designed to keep members informed about ongoing safety issues and to provide suggestions for reducing risk. Best practices are gathered from a variety of sources. They may be more or less stringent than individual corporate policies, and are not intended to be an official recommendation from SEAA. Always get approval and direction from your company officers on any new practice or procedure as these best practices may not work for all situations. Everyone benefits when a worker avoids injury. Submit your ideas for Safety Flash with the Near Miss/Incident Investigation Report form. Submit to executivedirector@seaa.net.