June 2016 is here, are you in compliance?

Youre shipping chemicals into my country and we cant read the label and we have
no idea whats in the container. Is it safe to open? What are the physical and
health hazards? This has been a global issue for as long as there has been
import/export. The United Nations recognized this and through years of
controversy, finally created the Globally Harmonized System (GHS). Thats right,
the intent is for every country that exports chemicals into a United Nations country
to label their containers with the same labeling system and provide a Safety Data
Sheet (SDS) that has been universally formatted to contain pertinent information.
What a concept, every country on the globe doing the same thing. Whens the last
time that happened? When the United Nations established GHS, they believed that
setting objectives for global harmonization would:
a. Enhance the protection of human health and the environment by providing an
internationally comprehensible system for hazard communication;
b. Provide a recognized framework for those countries without an existing
system;
c. Reduce the need for testing and evaluation of chemicals; and
d. Facilitate international trade in chemicals whose hazards have been properly
assessed and identified on an international basis.
http://www.unece.org/trans/danger/publi/ghs/ghs_rev02/02files_e.html

On March 26, 2012, the new OSHA Hazard Communication Standard (HCS) was
published in the Federal Register. This standard aligned with GHS and its
classification and labeling of chemicals in the United States, with these objectives in
mind, OSHA established a transition period for contractors to ensure employers
would be in compliance.

December 1, 2013 All employees who use, handle, or store chemicals

needed to ben trained in the new label system and safety data sheet (SDS)
format.

June 1, 2015 All chemical manufacturers, importers, and distributors must

be in compliance with the 2012 OSHA HCS requirements. This includes
classification of chemicals, preparation of safety data sheets, and preparing
GHS labels.

December 1, 2015 The grace period ended for shipping existing inventory
that had older labels. All shipments of chemicals must have the new GHS
compliant labels.

June 1, 2016 All employers must be in full compliance with the new HCS.
This includes having updated their written workplace hazard communication
program to incorporate the new GHS requirements and to have provided
training to employees on their new workplace hazard communication
program.

How does this effect the Steel Erection Industry? As of June 1, 2016 we should have
completed all the required steps to be in compliance with the standard. OSHA listed
the six steps that we needed to follow to ensure we are in full compliance.
1. Learn the Standard/Identify Responsible Staff
a. Have you designated a person who is responsible for your companies
Hazard Communication program? Responsibilities and implementation
should be assigned to a specific person
2. Prepare and Implement a Written Hazard Communication Program
a. Have you updated your policy to meet GHS requirements and all
workplaces have been provided with a written hazard communication
plan? This is intended to be site specific and it is required to be readily
available to your employees. Dont send that six inch three ring binder
full of MSDSs for chemicals that we will never see on site. We want
site specific.
3. Ensure Containers Are Labeled
a. Have you ensured that that labels on shipped containers remain in
place? What if the label is damaged or missing? What is your
company policy/process for replacing that label?
b. Are you labeling other workplace containers where required? No you
cant use the coffee can or the soda bottle. Nice try.
4. Safety Data Sheets (SDSs)
a. Have you replaced all of your Material Safety Data Sheets (MSDSs)?
MSDSs have been replaced by the SDS. The SDS is better formatted
and contains more complete information.
5. Inform and Train Employees
a. Have you trained your employees in the GHS labeling system and what
and where your sites SDSs are located?
b. Have you ensured that your employees are trained and understand
your companies updated company policy and procedures?
6. Evaluate Your Program
a. Finally. Have you reviewed your company policy to ensure all of the
above items are in place? The standard requires that you do this
before June 1, 2016 and then periodically to ensure compliance. Youre
going to need to do this again when new chemicals have been
introduced to the work place and when there are changes in the work
place and/or procedures

See

https://www.osha.gov/Publications/OSHA3696.pdf

for more information

I know, it sound like a lot of work but, hopefully you have been working on ensuring
compliance since 2013. OSHA only gave you two and a half years to get here. If
you answered yes to all of these questions, congratulations you should be in
compliance. If youre not sure, contact us, we can help. www.mscss.us
Troy L Clark
President
MSC Safety Solutions