Shifting successfully to GHS compliance
10:59 AM MDT | September 16, 2013 | By ANDY SCHERZ, SENIOR PRODUCT MANAGER/AMERICA AT EPSON
On 1 December 2013, a major regulatory shift in the chemical market will impact more than 43 million employees in the United States. In an effort to develop a safer, more efficient approach to the international shipment and transport of chemicals, OSHA has set forth new guidelines designed to standardize how chemical and hazardous information is communicated in manufacturing facilities and other workplaces. This framework is known as the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
As a global leader in chemicals manufacturing and exports, the United States accounts for 15% of global chemical shipments, exporting $80 billion annually. One challenge that has accompanied this international growth is the diverse method for classifying and labeling chemical products employed by different countries. The United Nations originally designed GHS as a universal set of guidelines that countries could follow to eliminate this confusion. Prior to international adoption, these differences proved expensive to regulate, led to costly shipping errors, and posed an unnecessary risk to employees who were unable to interpret chemical hazards accurately. The purpose of adopting these revised standards is to increase workplace safety, standardize products internationally, and increase productivity.
OSHA estimates that over 5 million workplaces in the United States are impacted by GHS guidelines. These standards are applicable to any industry where employees are potentially exposed to hazardous chemicals, including consumer-centric companies where common chemicals are present (i.e., cleaning supplies, pesticides, and pharmaceuticals). This will primarily impact chemical manufacturers, distributors, and importers that comprise approximately 90,000 facilities and 3 million employees nationwide. OSHA is the primary regulatory agency committed to overseeing GHS adoption through its revised Hazard Communication Standard (HCS), but several other US agencies—including EPA, Department of Transportation (DOT), and Consumer Product Safety Commission (CPSC)—will play a role in oversight.
GHS: Specific changes
There are four major areas related to GHS: hazard classification, labels, safety data sheets (SDSs), and employee training. The new measures require chemicals to be reclassified under the specific conditions in which they pose physical, health, and environmental hazards. GHS standards require manufacturers to consider the full range of available scientific data when classifying chemicals. Additionally, under this new classification, the hazards a chemical presents are further divided by severity. The benefits associated with these revisions ensure that hazard evaluations are more accurate and consistent regardless of manufacturer, supplier, or even country.
SDSs are currently referred to as material safety data sheets (MSDSs). These documents provide comprehensive product information for use in the workplace. Under GHS, SDSs will present product information under a new 16-section format. In addition to a change in the sequence of information, section two of the SDSs will contain comprehensive hazard information found on the product label.
Labels are a key facet of the new GHS standards. Beyond the new requirements, manufacturers must train employees on the new visual elements, including pictograms and color requirements, and incorporate color printing into their operations. Currently, label preparers need to only provide the identity of the chemical—any corresponding hazard warnings and the contact information of the responsible party with no uniform format are required.
The new GHS label structure provides a standardized indication of hazard classes and categories. These new requirements include a product identifier, harmonized signal word, pictogram, hazard statement, precautionary statement and supplier contact information. Furthermore, HCS adoption of GHS label requirements only applies to the classification and labeling of chemicals in the workplace.
GHS pictograms convey health, physical, and environmental information associated with a specific hazard class and category. Each of these pictograms includes a different hazard symbol on a white background with a red, square frame set on a point. While there are nine pictograms under GHS guidelines, the revised HCS only requires eight because the environment pictogram which pertains to aquatic toxicity is nonmandatory.
Harmonized signal words in the GHS system are meant to communicate a product’s level of hazard. On GHS-compliant labels, manufacturers must indicate either warning or danger to demonstrate this properly. Danger indicates that a product’s hazard is more severe.
Another major shift is the requirement to print labels in color. Under the revised guidelines, pictograms must be printed with red borders. OSHA permits manufacturers to produce labels via color printing or preprinted color labels. However, the use of preprinted color labels can result in incomplete label applications where chemical products display empty frames. This is not acceptable as a GHS-compliant label and can result in worker confusion and create inconsistency with DOT label regulations. Preprinted color labels can also add expenses such as inventory management and supply storage.
British Standard BS 5609, another key GHS requirement, takes into account the widening global trade landscape. For overseas transport of chemicals, BS 5609 requires that printed labels survive three months of salt-water submersion while maintaining print and adhesive integrity.
The first critical deadline for GHS adoption is 1 December. By this date, OSHA requires that all employees handling or exposed to hazardous chemicals be trained on new GHS label elements and SDS formatting. Since many companies abroad—including Europe, Australia, and Japan—and domestically have already begun shipping products using the new GHS-compliant labeling requirements, the training deadline has been prioritized to familiarize employees with the GHS label formats early on.
The next major phase for GHS essentially asks companies to become fully compliant with all the new provisions. This 15 June 2015 deadline requires complete reclassification of chemicals, integration of new label requirements, and GHS-formatted SDSs. One exception to this phase is the six-month grace period distributors are given to ship any products that are still labeled under the old system, ending 1 December 2015.
The final major deadline of GHS integration is 1 June 2016. By this date, employers must have updated their hazard communications plans as necessary to reflect any updates to label, SDS, and employee training requirements stemming from newly identified physical or health hazards.
On-demand color labeling as a solution
The multifaceted requirements for GHS adoption can present several challenges for companies, especially smaller businesses who must still adhere to the new guidelines. OSHA estimates the costs associated with upgrading label printing equipment and supplies at approximately $24.1 million annually. Using tools like Epson’s on demand color labeling technology, manufacturers can defuse the cost of preprint label inventories and transition to GHS compliance effectively.
For manufacturers integrating printing services into their operations, seeing faster benefits come from GHS standards means having a flexible system that can print durable, full-color labels, and diverse product information and label sizes on demand. Having a single-step process reduces inventory of labels to blank stock, minimizes the risk of labeling errors, and provides the flexibility to print out the precise GHS-compliant format and quantity desired while eliminating any concerns over printing incomplete labels.
Epson is one of the world's leading manufacturers of highly reliable point-of-service technology, including printers, precision printing mechanisms, digital image scanners, and mobile printing solutions. For more information, visit www.epson.com/packexpo.
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