OSHA’s Hazard Communication Standard (HazCom) full compliance deadline is fast approaching on June 1, 2016. At our Product and Technology Expo, Brady gave us a closer look into labels, Safety Data Sheet (SDS) changes, and top questions. To help you gauge your compliance, review the five steps to compliance and key questions and checklists presented by Brady.
Step 1: Develop a written Hazard Communication plan.
Develop a written HazCom plan that documents and outlines how your company responds to hazardous chemicals. The plan should include a summary of the hazardous chemicals and contain your hazard communication program or policy. Documenting your organization’s policy for dealing with hazardous chemicals will help you inform and properly train your employees.
Step 2: Inventory all of your chemicals.
Taking inventory of all of the chemicals being used throughout your facility is the most effective way to understand your chemicals and pave the way for GHS compliance.
Step 3: Establish and maintain a complete library of Safety Data Sheets (SDS).
Now that you have inventoried your hazardous chemicals, it’s time to find the new SDSs for all chemicals in your facility. Going forward, chemical manufacturers and distributors should provide an SDS with your new orders, but it is your responsibility to track down SDSs for chemicals currently on site and maintain your collection of SDSs going forward. Employees should have easy access to chemical SDSs at all times.
Step 4: Label all production finished goods, storage containers, pipes, and tanks.
All employers are required to update their workplace containers with new GHS-compliant labels. The intent of the new labelling system is to clearly communicate the chemical hazards to your employees (and customers). GHS labels include the product name, hazardous ingredients, applicable physical and health hazard statements, a “Danger” or “Warning” signal word and pictogram(s), along with supplemental and contact information.
Step 5: Train and communicate the elements of Hazard Communication to your workforce.
Regular employee training is essential to the success of your Hazard Communication program. It’s critical that your employees know how to read and interpret the hazardous chemical labels and SDSs to better protect themselves from chemical hazards. Make sure employee training (and re-training) is a priority!
Check our Brady’s whitepaper on Five Steps to Hazard Communication Compliance to learn more.
Five Key Questions to Ask Yourself:
- How many different chemicals do we use in our facility?
- Do we use secondary containers for our chemicals?
- Have I estimated the annual quantity of labels we’ll need?
- What’s my current labeling solution? Is it effective? Can it print in color?
- Do I need to print labels right away or can I wait a few days?
Your GHS Checklist:
- Reinforce previous employee training and continue to re-train for new employees or new chemicals added to your facility
- Document the inability of any supplier to provide SDSs (deviations)
- Assign personnel to be responsible for labeling and make sure they are properly trained
- Evaluate label printing systems, if needed, or preprinted labels from suppliers
- Audit and stress test your HazCom plan and update as necessary
- Stay ahead of the GHS deadline!
We hope this helps you understand GHS and better prepare for the GHS deadline. Check out the full presentation HERE. If you have any questions on your GHS compliance, please give your account manager a call.