How is the Globally Harmonized System Hazard Communication Standard going?
The final Globally Harmonized System (GHS) deadline was in June 2016, but that doesn’t mean employers can ignore Hazard Communication (HazCom) from here on out. On the contrary, it’s just as important as ever for companies to keep their HazCom management program going strong. Companies still need to maintain their safety data sheet (SDS) library, keep workers informed, and stay up to date with regulations. With that in mind, what should your HazCom priorities be going forward?
Make sure you’re GHS compliant.
By now, you should have a GHS SDS for every hazardous chemical on site. This includes not only your products, but your suppliers’ products as well. Since as many as half of all workplaces are still not fully GHS compliant, chances are good you have a few old material safety data sheets (MSDS) around.
If you still haven’t converted all your sheets to the new format, make doing so a priority. If one of your suppliers hasn’t provided you with up-to-date documents yet, the onus is on them to fix it; however, you should consider reaching out to delinquent suppliers. Taking the initiative may solve the problem and looks good to an OSHA inspector.
Continue HazCom training.
The deadline for GHS HazCom training passed years ago, but it is necessary to continue your GHS training program. New hires need to learn HazCom, and existing personnel require occasional refresher courses. OSHA inspectors will test your workers’ HazCom system knowledge, so it’s important to keep it fresh in their minds.
Keep your HazCom management plan updated.
If you’re serious about staying in compliance, you need to have a plan for keeping your HazCom system current. Your HazCom management plan should include a process for updating and distributing your SDS. This plan should also include periodic refresher courses for your employees to ensure they don’t get rusty.
We can expect HazCom standards to change frequently, and your HazCom management plan will need to change as well. The United Nations (UN) releases updates to the GHS every other year, with Revision 7 being released this year (2019).
Remember HazCom is an ongoing obligation, not a one-time task. Keep your HazCom requirements current to remain in compliance. OSHA has indicated it intends to update its Hazard Communication Standard, currently aligned with GHS Revision 3, to incorporate Revision 7 in 2019. OSHA had tentatively planned to issue a Notice of Proposed Rulemaking to revise the HazCom Standard in early 2019 and confirmed its regulatory plans while speaking at the Society for Chemical Hazard Communication’s (SCHC) fall 2018 meeting.
RETTEW can assist your company with policy reviews, behavior based program development, and required training. Contact Kelly Kramer, CECD, HEM, at 800.738.8395 to schedule a consultation.
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