GHS Chemical Labeling: When to Re-Label Existing Chemicals – Guest Blog

by Tom Smith, Product Manager, Brady Corporation

In Tom’s first Guest Blog for Q Source, he answers the question of GHS labeling for older chemicals.

Does your facility have chemicals that have been sitting on the shelf for a year or more? OSHA’s final Hazard Communication Standard deadline around the Globally Harmonized System of Classification and Labeling of Chemicals is quickly approaching. All customers must be fully compliant with the requirements, including those for Safety Data Sheets and chemical container labels, by June 1 of this year. Read on to learn if you need to re-label them with new GHS labels.

To answer this question, you first need to determine if you have chemicals on your shelves without GHS labels. Under GHS, OSHA required all chemical manufacturers to begin shipping their chemicals with compliant labels by June 1 of last year. OSHA also provided distributors with an additional six months (up to December 1, 2015) to make sure their inventories were updated and they were shipping chemicals with compliant labels. With this in mind, it’s entirely possible you may have ordered a chemical from your distributor before December of last year and received containers that have the previously used “right-to-know” or NFPA diamond labels.

Once you determine if you have older chemical containers without GHS labels in your facility, the next step is deciding whether you need to re-label them. The good news is that OSHA provides some guidance on this issue, explaining that “employers are not responsible for updating labels on shipped containers, even if the shipped containers are labeled under HazCom 1994.”

"To answer this question, you first need to determine if you have chemicals on your shelves without GHS labels."

Although you’re not responsible for updating older labels, you do have a responsibility when it comes to damaged labels or undisclosed hazards. OSHA explains that “the employer must re-label items if the labels are removed or defaced. However, if the employer is aware of newly identified hazards that are not disclosed on the label, the employer must ensure that the workers are aware of the hazards as discussed below under workplace labels.”

What sort of additional hazards may be undisclosed? NFPA 704 does not address hazards such as carcinogens (cancer causing) or mutagens (causing birth or genetic defects in the unborn child). However, the OSHA 2012 HazCom/GHS regulation does consider those hazards. Therefore, if you have an existing chemical that you know is a carcinogen, you also have to indicate that hazard and appropriate precautions on your label.

As with most regulations, the details are the key to understanding the appropriate actions to take. When it comes to employee safety, particularly with a new regulation, taking the conservative route with over-communication and thorough training is the ideal option. While you’re not required to re-label older chemicals, be sure the presence of the differing labels is made clear to employees to ensure they are safely handling all containers in your facility. As the full GHS implementation takes effect, these older containers will eventually be circulated out with future chemical orders and GHS-compliant labels will be used consistently.

Thanks, Tom! Your valuable information is extremely useful for making educated chemical safety decisions. We look forward to your future contributions to the Q Source Resource.

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Hazard Communication: Everything You Need to Know – Guest Blog

by Danielle Gallo, Product Marketing Specialist, Brady North America

Hazard communication is one of the most important occupational safety standards as it ensures employees are made aware of the potentially hazardous chemicals and risks to which they may be exposed. With the extreme importance placed on hazard communication, understanding the changes associated with the harmonization of the United Nations' "Globally Harmonized System (GHS) of Classification and Labeling of Chemicals" is critical.

History of Hazard Communication & the Globally Harmonized System

OSHA's Hazard Communication Regulation (1910.1200) was initially developed in 1983 with the goal of providing employees with the "right to know" of the hazards of chemicals that they were working around. This regulation accomplished this by mandating that all chemical hazard labels be applied to chemical containers. In addition, Material Safety Data Sheets (MSDS) needed to be supplied for each chemical, and be accessible to employees. Employees also needed to be trained on how to identify hazards and how to work around the chemicals.

Almost every country around the globe has guidelines or regulations with similar objectives to OSHA's hazard communication regulation: To warn employees or anyone coming into contact with the chemical about the hazards present. However, every country had a different way of not only categorizing hazards, but the classification process and how the hazards were depicted.

Big Changes for Better Compliance

Many changes were made to the hazard communication standard, but there are a few key changes that are greatly affecting the way facilities will manage their labeling process.

Revised Criteria for Classification of Chemical Hazards
Every chemical in the United States (there are approximately 880,000 different hazardous chemicals used in the US) needs to be re-classified by the chemical manufacturer per the GHS standard. This re-classification helps with the United Nation’s goal of streamlining chemical hazards globally.

Specified Format for Safety Data Sheets
The MSDS is now referred to as a Safety Data Sheet (SDS) and has a new format. The new SDS has 16 specified sections to help streamline the information provided, in addition to making it faster and easier for employees to find the information they need. These new SDS's will need to be filed and available for employee use once they are made available by the chemical manufacturer.

Revised and Standardized Labeling Requirements
Each primary container's chemical label must appear in the GHS format. This new format will still include the chemical name and manufacturer information, but also requires four new elements: a signal word, hazard pictograms, hazardous statements, and precautionary statements.

Secondary containers still need to be labeled per the employer’s hazard communication plan, with the label identifying the hazardous chemical and its appropriate hazard warnings (words, pictures, symbols or a combination). Secondary container labels need to provide employees with the specific information regarding the physical and health hazards.

Requirements for Employee Training: Labels, Safety Data Sheets
Due to the significant changes taking place, it is crucial that employees are fully trained on the changes made and how to read and identify chemical labels and hazard information.

There is an initial training requirement for employees. This training needs to cover the changes to the chemical label and SDS formats, understanding of new headings and the sequence of the SDS information, and an understanding of the standardized label elements (which includes the pictograms, signal words, and hazard and precautionary statements).

Even common worksite chemicals like Benzene, Toluene, or Xylene will have different information displayed on its chemical label and SDS than what employees are currently used to seeing.

OSHA's requirement for annual training on hazard communication has not changed and is still included in the changes to the regulation. As hazard communication continues to be one of the top cited OSHA regulations, it is essential to ensure staff and facilities are completely up-to-date with the changes in the regulation and the effect it will have on the workplace.

Timeline of Critical Compliance Dates
With the significant change made to the 29 CFR 1910.1200 regulation, OSHA has also provided deadlines for mandatory implementation dates.
December 1, 2013: By this date, every single US employee covered under the regulation needs to be initially trained on the changes to the regulation, specifically covering the overview of the changes to the regulation, the changes to SDS, and the changes to the hazard chemical label (focusing on understanding of the pictograms, signal word, hazard statements and precautionary statements).
June 1, 2015: All chemical manufacturers need to have re-classified their chemicals, updated the chemical label formats to the GHS format, and updated the chemical's SDS.
December 2015: All chemical distributors need to ensure that any product they are distributing has all of the updated information.
June 1, 2016: The final date for full compliance.

Q Source would like to thank our guest blogger, Danielle Gallo, from Brady Corporation. Thank you very much for your contribution to The Q Source Resource.

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