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Controlling your risk by Bob Carruth

As Risk Control Manager for the NCACC, Bob Carruth manages the operation of the Risk Control Team for the Risk Management Pools. The team assists members with development of safety policies and programs and identification of liability exposures and controls. Carruth is a Certified Safety Professional and is certified as an Associate – Risk Management.  For archives of this column click here

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Aug 29

Prepare now for the Global Harmonization System

Posted on August 29, 2013 at 9:20 AM by Chris Baucom

One of the hottest topics currently circulating through the safety community is that of the Global Harmonization System, or GHS.  It seems as though every safety conference over the past couple of years has included at least one presentation on the new workplace standard, and vendors are competing heavily to assist organizations with the new compliance requirements that come with the adoption of the standard.

Although many chemical substances have existed from the beginnings of time, it is only with the arrival of the industrial revolution and the founding of modern scientific methods over 100 years ago that the serious study of the use and application of chemical substances were cataloged and applied.  In 1907, with the establishment of the Chemical Abstract Service, or CAS as it is normally referred to, that the widespread identification and indexing of chemical substances began. 

Although many of the chemicals used in an industrial or domestic setting greatly improved both the economic vitality of organizations and the standard of living for many, there were also consequences.  Exposure to hazardous chemicals took their toll on America’s workforce. With the passage of the OSHA act in 1970, and the subsequent adoption and implementation of the Hazards Communications Standard in 1983 (it was fully implemented in 1987), US companies are now required to properly label and inventory all chemicals used in their organizations and train all of the employees on the chemicals that they could potentially become exposed to.

Although much has been made through the years of the HAZCOM standard, to include the need to maintain records on such things as bricks or correction fluid, it has been very effective in helping employees understand the hazards they face, and in the event of a hazard exposure, to provide the necessary information to quickly treat an injury or to clean up a spill.   Although the current CAS system has worked well, the rise of international manufacturing and shipping of common chemicals, as well as multiple distribution channels for those chemicals, has led to more and more administrative requirements and burdens as companies attempt to comply with the regulations.  Much of this was due to the confusion over the proper names for identical chemical substances and the inconsistent format seen in a variety of material safety data sheets.  

As noted above, the increased international trade in chemical manufacturing and distribution established a need for a consistent, simple system to classify chemical substances worldwide.  The United Nations took on the task of developing an international system, regulations and code to govern the classification and labeling of chemical substances.  There have been several revisions since the original adoption, and the United States is one of 67 countries that have integrated the new standards into its own chemical safety systems. 
With the implementation of GHS in the United States, there are several changes that will occur to the current OSHA HAZCOM standard.  First, employers will have the primary responsibility of educating all employees concerning the format for the new Safety Data Sheet and container labeling requirements.  The deadline for completion of this requirement is December 1, 2013. The second stage of implementation is for chemical manufacturers to convert all of their MSDSs to the new SDS format, and to ensure these SDSs are distributed to their customers.  This portion of the new standard must be completed by December 1, 2015.  As the final step in implementation, employers are required to have converted their MSDSs to the new SDS format for all chemicals in the workplace by June 1, 2016.

Although there are several vendors that will ensure your compliance for the right price, the stages can be completed at little cost to your organization.  At the NCACC, we will be providing to our pool members a training package to be used to educate county employees on the new requirements.  This package will include a PowerPoint presentation, sample Safety Data Sheet, a handout that can be used as an aid in learning the new Pictograms that will be part of container labeling in the future, and a compliance checklist that can be used to keep your organization on track.  

In addition to the training package, we are also investigating the possibility of subscribing to an online database, which can be used by our members as they begin to replace the current MSDS with the new SDS.  Given that it will not be needed until the 2015-16 timeframe, there will  be more information provided to you in the next 6-12 months regarding this tool. 
Yes, compliance with the new standard will take some time, and organizations need to plan now for its implementation internally.  However, with the right planning and foresight, this transition should be relatively painless.  If you have any questions or need additional assistance, please feel free to contact any member of our risk control staff.