Who Has to Be Trained?
See this guidance for understanding what you have to do for compliance with the hazard communication standard with GHS amendments.
The New GHS Label
Chemical manufacturers and importers have until June 1, 2015 to develop new GHS-compliant labels and put them on chemical containers. Chemical distributors have until December 1, 2015 to make sure the new labels are affixed to all containers that are shipped. However, some manufacturers and distributors are ahead of schedule and you may already have started to see the new GHS labels on your shipments of chemicals.
The new labels shipped with the container have to display all of the following elements:
- A pictogram with one of eight new hazard symbols inside a diamond-shaped box with a red border
- A signal word, either “Danger” or “Warning”
- Hazard statements, such as “Highly flammable liquid and vapor.”
- Precautionary statements, such as “Keep container tightly closed.”
- The product identifier, such as product name and/or code.
- Supplier identification, including manufacture name, address, and phone.
The label may also contain supplemental information, such as “Directions for use.”
There’s time to train. Just like SDSs, employers have until December 1, 2013, to train workers on the new chemical labels. However, it would be prudent to start training your employees how to read and interpret the new labels as soon as they begin to appear on shipments to your workplace.
Some things haven’t changed. Many of the other requirements for labeling chemical containers, including language requirements, exemptions for labeling pipe systems, and alternative labeling systems have not significantly changed, except labeling alternatives must be consistent with GHS label system.
Labels in English
The labels or other forms of warning must be legible, in English, and prominently displayed on the container, or readily available in the work area throughout each work shift. Employers with employees who speak other languages may add the label information in their language, as long as the information is presented in English as well.
Hazardous chemical containers must include either:
- The label shipped with the chemical container; or
- A product identifier and combination of words, pictures, or symbols that provide at least general information regarding the hazards of the chemicals and provide employees with the specific information about the physical and health hazards of the chemical.
Alternatives to Labeling
As an alternative to labeling all individual process containers, employers can:
- Substitute various types of standard operating procedures, process sheets, batch tickets, blend tickets, and similar written materials for container labels on stationary process equipment if they contain the same information as the labels.
- Post signs or placards that convey the hazard information if there are a number of stationary containers within a work area that have similar contents and hazards.
- Use alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) as long as those systems are consistent with the GHS labeling system.
All information supplied on the alternative labels must be consistent with the GHS label system; for example, there must be no conflicting hazard statement and pictogram.
Outdated Labels–Procedures to Correct
If an employer becomes aware of any significant new information about the hazards of a chemical, the employer must revise the labels for the chemical within 6 months of becoming aware of the new information. The employer must also ensure that labels on containers of hazardous chemicals contain the new information.