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Preparing for the Great Harmonization: Understanding OSHA’s new chemical labeling program

Written by  BSCAI

Can you imagine what it would be like for someone in Asia who speaks no English to work with an American-made cleaning chemical, where the label and all of the product warnings are displayed in English? What if the product’s label indicates that a cleaning chemical contains sodium hypochlorite (bleach) and the user is mixing it with a window cleaner containing an acid? Such a mixture can result in serious injury or even death.

It is because of this potential for harm that changes are afoot that will impact cleaning workers around the world, especially in the United States. The Occupational Safety and Health Administration (OSHA) has recently decided to adopt the Globally Harmonized System (GHS) for chemical labeling. While many cleaning professionals may already know about these changes, some may not know exactly what the program will entail.

The new system will change the laws concerning the labeling of all types of chemicals, including cleaning solutions. According to U.S. Secretary of Labor Hilda Solis, “Revising OSHA’s Hazard Communication standard [and aligning it with labeling and hazard warnings found in other countries] will improve the quality and consistency of hazard information, making it safer for workers to do their jobs and easier for employers to stay competitive.”

More specifically, the changes are being adopted to achieve the following goals:

  • Less confusion in the workplace as to how to handle hazardous chemicals
  • Greater safety training to help prevent accidents and injuries
  • Quicker, simpler, and more consistent access to information on these products
  • A potential cost savings of an estimated $475 million (this includes injuries to cleaning workers, absenteeism, reduced worker productivity, etc.)
  • Fewer trade barriers by harmonizing hazard warning systems with those in other countries around the globe

At first blush, the changes that are coming as a result of this “harmonization” may appear a bit daunting. For instance, cleaning workers will notice that the Manufacturers Safety Data Sheets (MSDSs) they have used for more than 30 years have been replaced with new Safety Data Sheets (SDSs). OSHA has mandated this change hoping to standardize chemical labels, so cleaning professionals—no matter where they are located around the world—will always be able to tell exactly what risks a product may pose, regardless of where the product was manufactured or is being used.

While there is a transition period involved in the various components of GHS, cleaning professionals can take a number of steps right away to better prepare for this new program:

Perform a chemical inventory. The first step toward preparing for the GHS should be conducting a thorough inventory of all cleaning chemicals currently used in a facility. This should include information such as what products are stored, where/which tasks they are used for, and who the manufacturer is for each one. The inventory should also note whether a product is conventional or Green-certified, the age of the product (if it has not been used for several months, proper disposal may be called for), as well as where it is stored. Finally, the availability of an MSDSs or a new SDSs for each product should be indicated.

Transfer to SDSs. Cleaning professionals will soon be required to replace MSDSs with SDSs. This can be a rather cumbersome process, especially if many different chemicals are being used in a facility. Working with a jansan distributor can help. In many cases, their suppliers, especially larger manufacturers, will be disseminating new SDSs, which they can then pass along to their clients. Additionally, SDS service providers now offer software programs that can help with this conversion.

Become familiar with the new pictograms. A big part of the harmonizing process involves the expanded use of hazard communication pictograms. The goal of this change is to make warning labels easy to understand, regardless of the user’s country of origin or reading ability. According to Bill Balek with the legal department of ISSA, “A pictogram consists of a symbol on a white background framed within a red square-on-point border designed to communicate a distinct hazard graphically.” For most people, especially those in North America, the pictograms will be easy to understand and decipher. These new pictograms can be downloaded from the OSHA website at www.osha.gov. Cleaning professionals should begin adding these new labels to their products right away—especially to any products that are particularly dangerous—so all workers can become familiar with them.

Develop staff training programs. Training is a key component of adopting the GHS program. For cleaning professionals, the training process focuses on how to read and understand the new labels. Those facilities that may use chemicals imported from other countries should begin training their employees as soon as possible, since some foreign manufacturers may already be using GHS labels. Staff members will need to know how to read the new labels, how to interpret the pictograms, what the various signal words in the pictograms mean, and how to identify hazard and precautionary statements. Facility users should also be made aware of the GHS program, especially the pictograms mentioned earlier.

As noted, OSHA has incorporated a transition process in adopting GHS. For instance, chemical manufacturers have until June 1, 2015, to place the correct GHS labels on their products. Below is a listing of some of the key phase-in dates that FMs and cleaning professionals should be aware of:

  • December 1, 2013: Train employees on the new label elements and the SDS format (this task will need to be handled by cleaning contractors or facility managers)
  • June 1, 2015: Compliance with all modified provisions (this specifically addresses chemical manufacturers)
  • December 1, 2015: Distributors shall not ship containers unless they have the new GHS labeling system
  • June 1, 2016: Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards (manufacturers, distributors, contract cleaners, and facility managers)

However, many U.S. manufacturers are expected to start incorporating some of these changes long before the mandated times. Because of this, cleaning professionals should start now to better understand the new guidelines and their ramifications in order to be well prepared once the program becomes mandatory. Further, while changes like these are invariably met with some resistance, remember that these new guidelines are primarily designed for the safety of cleaning workers—and safety should always be a top priority.

Paul M. Wildenberg is Vice President of Sales, North America, for Charlotte Products/Enviro-Solutions LLC, leading manufacturers of professional cleaning chemicals. He may be reached through the company website at www.enviro-solution.com.

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