A new OSHA law concerning the classification and labeling of chemicals, know as GHS, becomes law effective on May 25th, 2012.
Is that a sexy title or what?
From the feedback I’ve received, many different types of readers follow “A Clear View Through Clean Windows.” For those running a window cleaning business or something similar, I periodically post important safety information.
Please let me know if you find this information useful.
Safety is a serious topic and our company, Fish Window Cleaning, adheres to all OSHA regulations.
Here’s some important OSHA related information from our company’s Risk Manager, Tom Patton.
Tom works for Barrett Business Services, Inc. (BBSI), our Professional Employer Organization (PEO), and helps make sure we receive up-to-date safety techniques and information, and he monitors us regularly to make sure we follow our safety training program and conform to all OSHA safety regulations.
Make it a SAFE Day!
John Gran – Owner
Fish Window Cleaning – Los Angeles South Bay
Remember: Safety is everyone’s responsibility!
OSHA GHS Final Rule Effective Next Week
The Globally Harmonized System (GHS) finally makes its debut. But don’t worry, there’s plenty of time yet to comply.
OSHA has announced that the final rule for GHS, or Globally Harmonized System of Classification and Labeling of Chemicals, will become law effective May 25, 2012.
The effective date of the final rule is 60 days after March 26, the date of the rule’s publication in the Federal Register.
The new GHS rule will be added to OSHA’s existing hazard communication standard, or worker right-to-know law.
OSHA says the GHS rule will help prevent 43 worker fatalities and 585 occupational injuries and illnesses from chemical exposures every year.
According to OSHA, the GHS rule will affect over 5 million workplaces and 40 million workers.
There are two primary groups of employers that will be affected by the GHS rule:
- 90,000 employers that are chemical manufacturers, importers and distributors
- 5 million other employers where their employees use, handle, or store chemicals
4-Year Transition Period
OSHA will allow employers the following phase-in or transition period to comply with the new GHS requirements:
- December 1, 2013 – All employers that use, handle, store chemicals. Train employees about the new chemical labels and safety data sheets or SDSs (formally material safety data sheets or MSDSs).
- June 1, 2015 – Chemical manufacturers, importers, distributors Comply with all the requirements of the GHS rule, except compliance with GHS label requirements for distributors by December 1, 2015.
- December 1, 2015 – Chemical manufacturers, importers, distributors All shipments of chemical containers must include the GHS-compliant label (signal word, pictogram, hazard statement, and precautionary statement).
- June 1, 2016 – All employers that use, handle, store chemicals Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
Options During Transition
During the phase-in period, employers would be required to be in compliance with either the existing hazard communication standard or the revised standard with GHS, or both.
OSHA recognizes that hazard communication programs will go through a period of time where labels and SDSs under both standards will be present in the workplace. This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.
What Will Cal-OSHA Do?
Several of you highly knowledgeable recipients of my newsletter asked me if Cal OSHA will be adopting this Federal Standard.
I can only say this: Cal OSHA must be equal to or better than Fed OSHA Standards and I fully expect Cal OSHA to do the same with this Regulation.
It’s only a matter of time.
With the hazard communication standard already a regular fixture on OSHA’s most frequently cited standards list, it’s more important now than ever before to understand how GHS affects your hazard communication obligations.
It’s important to remember that your hazard communication requirements will not be reduced by the Globally Harmonized System (GHS); they will simply be modified to support the new system.
Though implementing GHS does not involve a total rewrite of the hazcom standard, there are still a lot of changes coming your way. Pretty much everyone who uses hazardous chemicals has some responsibility…but some more than others.
- Chemical manufacturers and importers have some work to do around re-authoring MSDS and turning them into safety data sheets (SDSs). They also have to rewrite labels and warnings to make them GHS compliant.
- Resellers and distributors need to get the new SDSs and labels and distribute them to customers.
- And, of course, employers have plenty to prepare for, too.
Get Ready, Get Set
Here are 8 steps your organization can take during the phase-in period to prepare for full compliance with GHS:
- Have an hazard communication plan. Maintain a checklist of key plan components and review it annually.
- Inventory your on-site chemicals and make sure you have a complete library of MSDSs and SDSs as you get them.
- Prepare yourself for the eventual switchover from MSDS to SDS. If you’re still using paper, consider transitioning to electronic system.
- Make sure your alternative labeling system is GHS compliant.
- Start developing a training plan for your employees now. Have a plan and make sure employees are ready to read GHS compliant SDSs and labels.
- Stay current on OSHA, including federal, state and local requirements. Keep an eye on GHS, looking out for key dates that will have an impact on your plan. (Note: That’s where Safety.BLR.com can help. This would be a great time to check it out!)
- Request GHS-compliant SDSs from your chemical vendors. Talk to your chemical suppliers and ask about their plans to transition to GHS. Make sure your staff is on the lookout for SDSs with new shipments.
- Stay SARA compliant. Update local and state emergency response agencies when new chemical hazard information becomes available.
(SARA is the Superfund Amendments and Re-authorization Act, (SARA) which requires facilities who are subject to OSHA’s hazardous chemical requirements to submit MSDSs or a hazardous chemical list to local and state authorities.)
By following these steps, you’ll be well on your way to preparing for the new requirements.
For Additional Information on GHS:
Be Safe Everyone!
About the Author
John Gran (@FishSouthBay) is an entrepreneur and former marketing and product development executive who has grown his successful Fish Window Cleaning franchise in the Los Angeles – South Bay area to become a leading professional in window cleaning services for business owners and home owners.
With his popular blog A Clear View Through Clean Windows, John shares his window cleaning expertise by addressing topics and answering questions that customers continually ask him during his day. He also uses window cleaning pictures, inspirations and stories about his business to demonstrate the fundamentals for building a strong, healthy, thriving business.
John lives & works with his wife Cynthia in Redondo Beach, CA (she runs the business too!)
If you have a question or would like window cleaning services click Here or Call 310-973-3474 for a Free, on-site written estimate.