By Evan Gurley
By Dec. 1, 2013, all precast plant employees must be trained to identify new, internationally standardized chemical hazard labels and learn how to use new safety data sheets (SDSs). So how will OSHA’s implementation of the new Globally Harmonized System (GHS) into its Hazard Communication Standard (HCS) affect precasters and their approach to hazard communication?
First, let’s take a brief look at what GHS is and why OSHA decided to accept this new standard. According to OSHA, GHS is an international approach to hazard communication, providing criteria for classification of chemical standards, and a standardized approach to labeling elements and safety data sheets (SDSs). GHS was formed under an international umbrella to manage the process for a new universally recognized labeling system. The result is a United Nations document known as “The Purple Book,” or the “Globally Harmonized System of Classification and Labeling of Chemicals,” which can be used by regulatory agencies such as OSHA to establish mandatory requirements for hazard communication.
Standardized hazard labels
OSHA states that this new document provides harmonized classification criteria for health, physical and environmental hazards of chemicals. It also includes standardized label elements that are assigned to these hazard classes and categories, and provides the appropriate signal words, pictograms, and hazard and precautionary statements to convey the hazards to users. A standardized order of information for SDS is also provided. Pharmaceuticals, food additives, cosmetics and pesticide residues in food will not be covered at the point of intentional intake, but will be covered where workers may be exposed and in transport.
The primary use of the SDS is in the workplace. It is used as a source of information about hazards and to obtain advice on safety precautions. The SDS should provide comprehensive information about a chemical or substance or mixture.
Why GHS is needed
The new GHS will eventually improve the safety and health of workers through more effective communication on chemical hazards – plain and simple.
The original HCS, implemented in 1983, is a performance-oriented standard, essentially allowing chemical importers and manufacturers to convey information on material safety data sheets and on labels in whatever format they choose. While this has worked in the past, OSHA believes that a more standardized approach to classifying and conveying hazardous information and harmful effects that the chemical poses will be more effective and provide continuous improvements in the American workplace.
Another major benefit of adopting GHS is the communication and the standardization among other countries that interact with the United States in the chemicals trade. Many times international requirements differ, causing confusion and conflicts. For example, labeling in other countries may be difficult to read or the terminology may not be well understood among other countries, leading to confusion and possibly the incorrect handling of chemicals. The change to GHS will minimize these issues by standardizing the labeling and information of chemicals imported and exported.
Phase-in period for GHS
When will this begin to affect precasters? The answer is now. While full compliance of all modified provisions of this final rule doesn’t take effect until June 1, 2015, employee training on the new label elements (pictograms and signal words) and SDSs needs to begin no later than Dec. 1, 2013.
Another significant change comes with training workers on the harmonized training provisions. GHS does not include training provisions, whereas the revised HCS requires workers to be retrained within two years of the final ruling publication. GHS recognizes training is essential, but it does not require training.
For a complete side-by-side comparison of the existing versus the revised rules, visit osha.gov/dsg/hazcom/side-by-side.html.
GHS goal: increased safety
The development of the GHS has been a long and complicated process. OSHA expects that the modifications to the HCS will result in increased safety and health for the affected employees and reduce the numbers of accidents, fatalities, injuries and illnesses associated with exposures to hazardous chemicals. This internationally uniform system for hazardous chemical labels and more comprehensive SDSs is a significant improvement in accurate chemical identification that will benefit every precast concrete manufacturing facility through increased employee safety.
Evan Gurley is a technical services engineer with NPCA.