Beginning December 1, 2013, OSHA will begin its multi-year roll-out of its mandatory transition toward the Globally Harmonized System (GHS) for labeling potentially hazardous chemicals. The transition will bring U.S. standards into parity with those already introduced in other countries around the world, and, according to OSHA, will ease the process of importing and exporting chemicals between the U.S. and other participating countries — a harmonized system means that by complying with one, a company complies with all. And the agency claims the system, by endorsing better at-a-glance knowledge of a chemical and its potential hazards, will be able to save a significant number of lives and prevent even more on-the-job injuries.
And while improved safety is always a high priority among well-intentioned manufacturers, there is always a natural and understandable fear about implementing changes in light of a new regulatory landscape. There’s overhead in capital investments and additional training, and a fear that safety experts may be missing out on some critical component of the new rules. In order to help assuage some of those sentiments, and to give concerned safety experts more information about the upcoming changes, we sat down with Grainger’s Kelli Baker, who holds both air and ground shippers certifications for dangerous goods, has OSHA 30 certification and has facilitated various webinars and seminars related to GHS.
Manufacturing.net: What do the GHS changes mean to manufacturers?
Baker: For chemical manufacturers, changes will include classifying the products and creating the GHS specific labels and data sheets as well as training. For manufacturers in other industries the changes will include training to understand the new GHS specific labels and data sheets, as well as an overall check and adjust to their facilities hazard communication program.
Manufacturing.net: How many of the manufacturers you deal with are aware, much less prepared for, the upcoming GHS roll-out?
Baker: The majority of Grainger’s customers have heard of GHS. The preparation varies by business; it seems the larger facilities, which have a designated safety team and are usually present in multiple countries, are more prepared than the smaller facilities.
Manufacturing.net: Providing GHS training is the first part of the equation. What have you been recommending or offering to customers in that regard?
Baker: We started educating our customers with webinars in 2010. Through our various newsletters and emails we have communicated the changes as they happen. The webinars continued and became more frequent after the announcement of the final rule in March 2012. We also hosted a webinar specific to the training requirements and developed an online course to help our customers meet OSHA’s Dec. 1, 2013 compliance date.
Manufacturing.net: What kinds of problems are manufacturers struggling with right now when it comes to that training?
Baker: The pain-points our customers tell us about most often are finding the time to train employees as well as determining who will do the training. Many folks are under an impression that the training needs to be completed by a certified trainer, which is not the case; training can be done in-house. We have also heard questions around who needs the training and what the training specifically requires. OSHA has created a training requirement fact sheet to help with some of the questions related to requirements.
Manufacturing.net: Obviously, much of the burden with the new GHS requirements is on the chemicals producers themselves, in terms of ensuring that products meet the new labeling guidelines. But is there anything else that ordinary (non-chemical) manufacturers need to be aware of?
Baker: The most common confusion is around the workplace labeling system, specifically as it relates to the National Fire Protection Agency (NFPA). Employees are used to seeing the 0-4 hazard rating used on the NFPA system. OSHA uses a numbering system as well which is inverted from NFPA. Under NFPA, the higher the number means the more severe the hazard. GHS uses a numbering system of 1-5 hazard rating, and the lower the number means the more severe the hazard. There is some concern in the industry that individuals will not understand whether they are seeing the NFPA numbering system or the GHS numbering system. However, OSHA does not believe this will be an issue because the GHS numbering system is only required in Section Two of the SDS; it is not required on the workplace label.
Manufacturing.net: Any flaws or missteps that you think need a second look? Are there people who think these kinds of changes are unnecessary?
Baker: After the final rule regarding GHS was initially published, there was some criticism about the inclusion of combustible dust as well as Threshold Limit Values (TLV’s) in the guidelines. To address the criticism, OSHA has created numerous interpretation letters and fact sheets. It is important to note that changes to the first published standard regarding GHS are anticipated as it is considered an evolving document.
Manufacturing.net: What do you think some of the main advantages are of the new system?
Baker: There are several advantages to GHS. The most important is the new system’s ability to reduce workplace fatalities and workplace injuries through streamlining labels and data sheets. Too often, hazard information is either misread or misinterpreted. With adequate training, GHS will reduce those errors related to miscommunication. A second advantage is the scope of GHS; the fact that the new system will be used globally will make it easier to engage in international trade and partnerships.
For more information, visit the GHS landing page on www.grainger.com.