What will change?
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Under GHS, manufacturers must use specific criteria to evaluate the severity of the health and physical hazards their products pose. Based on the assessment, they are to assign them a hazard classification. The classification, in turn, governs the information they must include on the product label and safety data sheet, and ultimately how the product must be handled.
Currently, manufacturers must identify the chemical and appropriate hazard warnings on product labels. Going forward, they are required to include hazard information on labels and safety data sheets using four integrated communication elements:
• A pictogram, a symbol displayed on a white background inside a red, diamond-shaped border that is designed to convey—without language—the type of hazard.
• A signal word, a one-word alert indicating hazard severity. Under the modified hazard communication system, “danger” will describe more severe hazards and “warning” will indicate those that are less severe. No signal word indicates a relatively low hazard.
• A hazard statement, a description of the nature of the hazard and, when appropriate, its severity.
• Precautionary statement, a description of what to do to prevent or minimize the hazard.
In addition, the format of the safety data sheet will be standardized, a change intended to make finding hazard, first aid and personal protective equipment (PPE) information easier.
Finally, one other change is likely to result from the conversion to GHS, though not immediately. The price of chemicals may eventually increase as there are significant costs associated with the development and manufacturing systems to comply with this regulatory change.
Complying by Dec. 1, 2013
You probably don’t need to be reminded that the Dec. 1 training deadline is just weeks away. As a restaurant owner, you may rely on training tools developed by suppliers or others, but OSHA will hold you responsible for making sure all employees, including temporary and contract workers, who may come into contact with chemicals understand the new system and that their training is documented.
Resources are available to help you prepare for training and the transition to GHS-labeled products. Check with your chemical suppliers: They may want to help you meet your compliance deadlines. For example, they may have prepared materials and tools designed to help you train employees.
Also visit the OSHA website https://www.osha.gov/dsg/hazcom/index.html to download the fact sheet, “December 1st, 2013, Training Requirements for the Revised Hazard Communication Standard,” for more details about the new hazard communication system and what you need to do to comply.
Training your employees before the Dec. 1 deadline will be well worth the effort. Knowing that you have taken steps to help employees stay healthy and safe—and to protect your business from OSHA violations and fines—will provide ample payoff.
Steve Christenson is global regulatory affairs v.p. and associate general counsel for Ecolab Inc., responsible for managing the company’s product registration, chemical substance clearance, product safety, transportation and trade compliance programs. He is also directing a multi-million-dollar IT initiative to standardize Ecolab’s chemical safety hazard communication to customers in the U.S., Canada and more than 50 countries around the world.