As you may be aware, OSHA has modified its Hazard Communication Standard (HCS) in March 2012 to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
What is GHS?
In 1992, the harmonization of classification and labelling of chemicals was one of six program areas that were endorsed by the United Nations General Assembly to strengthen international efforts concerning the environmentally sound management of chemicals. GHS provides a global standard for:
- Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria; and
- Communicating hazard information, as well as protective measures, on labels and safety data sheets (SDS).
What is the impact of GHS to Basic Coatings?
All Basic Coatings labeled products manufactured after June 1, 2015, will be labeled with the new GHS labels.
What changes can customers expect to see?
Between now and the June 1 deadline, we will begin the transition to the GHS labels and SDS:
- Labels will now have pictograms surrounded by a red diamond shaped border for materials that have health or physical hazards.
- The name material safety data sheet (MSDS) will change to safety data sheet (SDS).
- GHS requires the adoption of a new 16-section format of SDS as the standard, which is the same as our current Basic Coatings MSDS.
- Certain standardized precautionary statements are required on SDS and labels.
To help better understand GHS, we have put together a list of frequently asked questions.
Q. How will the user know the SDS is the new GHS version?
A. The SDS sheet will be labeled Safety Data Sheet and not Material Safety Data Sheet, will contain the 16 specified sections, and have its GHS classification and Pictograms in Section 2 if applicable.
Q. When do the new SDS sheets and labels have to be provided by manufacturer?
A. June 1, 2015
Q. When do the new SDS sheets and labels have to be provided by the distributor?
A. New SDS Sheets must be provided by June 1, 2015. New labels by December 1, 2015
Q. Is there a deadline for end users to use chemicals with current labeling?
A. No, currently OSHA has not issued any use date. From an OSHA perspective, customers may use current inventories until they are depleted.
Q. Will a facility need to keep old MSDS sheets?
A. Yes. Manufacturers, distributors and end user employers must keep old safety data sheets for 30 years or equivalent records containing the chemical identity and information.
Q. During the transition period, June 1, 2015 until December 1, 2015, can an end user have the option to use either the old MSDS or the new SDS sheet?
A. No. A distributor or end user employer should acquire or request the GHS SDS by June 1, 2015. A distributor can continue to sell the older version label until December 1, 2015. A customer can continue to use a product with the older version label but must refer to the new GHS SDS for the product.
Q. Could there be more than one GHS Pictogram on a label and SDS?
A. Yes. If there is more than one hazard, multiple Pictograms may be used.
Q. If the product is not classified hazardous, will it require a Pictogram?
A. No, only chemicals classified as hazardous.
Q. Can Pictograms have a black border?
A. No. The Pictogram must have a red border, white background and black hazard symbols.
Q. Do I need to have an SDS for every chemical used in the facility?
A. No, only if it is a hazardous material. But as a best practice users should request SDS for all chemical products used by an employee in their normal job function.
Q. Will DOT Hazard Labels be on product containers in addition to the new GHS Pictograms?
A. Potentially. Shipping cartons and containers will have DOT hazard labels and product containers will have the GHS Pictograms. If a product container is also the shipping container, such as a 55 gal drum, both the hazard label and the GHS pictograms will appear on it.
Q. Do I need to update the facility HAZCOM Program with the new GHS requirements.
Basic Coatings is committed to complying with the requirements of HCS 2012/GHS and is taking every step necessary to ensure that we are prepared to successfully transition to the new GHS label and SDS formats in the U.S. by the June 1 deadline.