It’s been just over a year since the Occupational Safety and Health Administration’s (OSHA’s) revised Hazard Communication standard (HCS), Title 29 Code of Federal Regulations (CFR) 1910.1200 went into effect last June. The GHS is a universal system that will assure all chemical products that are shipped and used around the world have a common system for notification of hazards to the end user. Pictogram labels and Safety Data Sheets are two required tools businesses use to accomplish the goals of the GHS.
Last summer, employers were required to update workplace hazard labeling and communication programs as outlined by the new GHS standards and provide employee training.
GHS Violations
For a complete look at the GHS standards, click here.
While many businesses have made changes and updates to their hazard communication systems, issues with hazard communication standards are usually on OSHA’s Top Ten Most Frequently Cited Violations. The Hazard Communication Standard 1910.1200 had a total of 5,655 violations in 2016, down about 20 citations noted for 2015. The Top 5 sections cited were:
- 1200(e)(1) Implementation of hazcom communication – 1,833
- 1200(h)(1) Training – 1,466
- 1200(g)(8) Requirement to maintain SDS- 464
- 1200(g)(1) Requirement to develop SDS – 386
- 122(h)(3)(v) Explanation of label received on shipping containers. SDSs including the order of information and how employees obtain and use the appropriate hazard information – 334
The top hazcom violation – implementation of hazcom communication – many times centers around businesses properly labeling secondary containers. For example, when you get a chemical from a manufacturer, the container is compliant with GHS requirements. But many companies use a smaller amount of the chemical in a smaller and more portable container and THIS is the container that must have a proper GHS label to inform employees exactly what is in the bottle. These containers with “migrated” chemicals are the containers OSHA is finding are in violation of GHS.
Our custom designed GHS labels offer an easy solution for labeling chemicals after migrating to secondary containers. Our label makes it easy to translate the NFPA and/or HMIS language into the GHS label. Simply use the chemical’s primary label and mark the blank GHS secondary label accordingly. Our GHS labels feature a checkbox for each of the pictograms that represent each hazard. We recommend using a fine point sharpie marker to mark the labels with the appropriate safety information. Our GHS labels are available in small and large sizes and come in a roll of 100.
See our video of how simple and effective our GHS labels are:
Link: https://youtu.be/LknOu1He4-4
SDS Compliance
Employers are required to have an SDS available for each hazardous chemical they have on site, and the information contained on them is the basis for training their employees on the hazards of the chemicals to which they are exposed, according to 29 CFR 1910.1200(h)(3)(iv).
A company’s SDSs play a really important part in showing proper recordkeeping for employers in situations where the chemicals at their facilities have no OSHA permissible exposure limit (PEL). Currently, there are about 500 chemicals that have an established PEL, and the SDS affords the safety decision maker facts to make informed decisions on their potential hazards while conducting a hazard assessment for new chemicals introduced into the workplace.
Safety Data Sheet (SDS) Best Practices
Here are some industry best practices to help keep your SDS library up to date and compliant based on the top five cited sections of OSHA’s Hazard Communication Standards:
- You can’t just write your hazard communication plan in a book. You have to execute the written hazard communication program and look for implementation and improvement. And remember, once your hazard communication plan is written down, you’re responsible for it happening – especially when an OSHA inspector shows up. Key SDS components companies need to make sure are written into their program include:
- Identify employee(s) responsible for obtaining/maintaining the SDSs
- Explain how the SDSs are maintained
- Instructions for employees to obtain access to SDS, as well as a plan for an electronic system and backup plan in the case of computer or power failure.
- Provide information on what to do if an SDS is not received with the initial shipment of a chemical
- What to do if the SDS is missing information or is it doesn’t appear to be the most current version of information available.
- Another key to having compliant SDSs and hazard communication plans is to have your hazard communication employee training plan clearly outlined via SDS and recorded as being complete (when, where, etc.). OSHA has explained inspectors will evaluate the effectiveness of an organization’s hazard communication training by reviewing the program materials (via SDSs) and interviewing employees and management. The employees interviewed are not expected to recite verbatim all the information covered in the training, but they should be aware of the hazards to which they are exposed, understand how to use information on the SDSs and know and follow job safety practices and protective measures. Conducting random observations and employee interviews to verify hazard communication training retention is a best practice for companies to undertake.
- A third common hazard communication violation centers on maintaining good SDS. Three points to keep in mind when keeping good SDSs:
- Employers do not need to maintain SDSs for non-hazardous chemicals.
- The method (i.e., paper or electronic) of maintaining SDSs is not as important as the requirement that all employees have immediate access to the SDS in their work area.
- Employees must have uninhibited access to SDSs on all shifts. Some violations have occurred in companies where there were compliant SDSs – but the third shift employees could not get to them because they were locked in an office that was not accessible during their shift.
OSHA makes a big deal about GHS labeling and SDS because they are important facets of companies making the effort to keep employees informed and safe around hazardous chemicals as well as documenting an employer’s efforts to accomplish safety goals. While updating GHS labels and SDSs may take a little time, they are relatively inexpensive ways to meet OSHA standards and – more importantly – keep employees safe at work.
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