One of the brilliant issues, at least for me, raised by Niall O’Malley of EHS Today article last October about GHS was whether providing workers access to information was enough and could satisfy what was required of employers by the implemented GHS HAZCOM update. O’Malley challenged the slogan associated with hazard communication (“Your Right to Know”), saying that just because employers provide workers all the resources they need doesn’t mean they can perform their job (i.e. chemical handling and storage) 100 percent effectively. After all, what if workers don’t understand the HAZCOM standard? Or, what if they do not understand what has been written on those material safety data sheets that are available to them? But according to OSHA officials and safety experts, the GHS update will bridge all gaps relating to OSHA’s previous standards. Is this really the case?
O’Malley’s opinion is something that resonates in me and I think, speaking for most safety technologists, is something worth examining. And with the deadline coming up in just a couple of weeks, the whole issue is something worth looking at. How would training for GHS become effective and sufficient enough to make sure workers fully understand how to apply the provisions of the standard?
I think the first thing to know is to first, dissect the provisions of the GHS update. Basically, what OSHA did was align its HAZCOM standard to the Globally Harmonized System of Classification and Labeling of Chemicals. Before, there was little way for people to tell the difference between various hazard categories, or know what they meant. The GHS update has basically remedied that problem by adding a section to safety data sheets that indicate the information about the chemical hazard. Specifically, per OSHA, the GHS update covers:
Hazard Classification: Categorizing health and physical hazards, and mixtures;
Labels: The GHS update requires chemicals manufacturers and importers to include a harmonized signal word, pictogram and hazard statement for every hazard class on the label. Accompanying warning statements should also be provided on the label.
Safety Data Sheets: The material safety data sheets will now be modified to a 16-section format.
Information and Training: Workers have to undergo training for then update before December 1, 2013.
The second most important thing is to identify and compare the previous hazard communication standard with the updated HAZCOM standard. Trainers and employers should present a side-by-side comparison of the two standard versions for workers during training, if they may. Better yet, they should provide workers refresher training before asking them to take GHS. This way, workers would be able to effectively note the changes between the two.
For further information on GHS HAZCOM Training, read these previous blog posts I wrote on changes with GHS label elements.