Page 55 - Occupational Health & Safety, May 2017

tory list located in your written HazCom program (in the event that you don’t have a chemical inventory list in your written plan, now is the time to do this because it’s a mandatory component of a compli- ant OSHA HazCom program). Take your time walking through the facility, noting any inconsistencies with chemicals, loca- tions, or amounts. Make sure the chemi- cal manufacturers’ names, addresses, and telephone numbers line up with what is recorded on the inventory list and SDS; this will be key if you need to contact them for any updated documentation.
Once you’ve completed the physical inventory of the chemicals in your facility, the next step is to ensure that you have a current SDS for each chemical on your list. During the official GHS transition period, many downstream chemical users experi- enced a delay in receiving updated SDSs to replace their older formatted MSDSs from manufacturers. While OSHA recognized this issue, the agency made it clear that it was your responsibility as the employer to take measures to ensure your facility had the most updated SDSs available to workers for products coming in following the dead- line period without updated SDSs.
Chemical manufacturers and distribu- tors are required to send a GHS-aligned SDS of a chemical with the first or the next shipment after an update to the SDS docu- ment occurs. If you’ve received a first or next chemical shipment on or after June 1, 2015, and it didn’t include the new SDS, you should have requested it from the sup- plier. If the supplier didn’t have one ready, you should be prepared to relay that infor- mation to OSHA. In other words, you need to be able to demonstrate to OSHA that this was not something you accepted passively and made all attempts to rectify.
Any attempts you made to obtain the documents should be recorded, includ- ing the date of the original shipment and exactly what manufacture documentation was missing (i.e., updated shipped label, up- dated SDS, or both), along with records of any calls, emails, and letters to the supplier showing your attempts to resolve the matter.
Fortunately, today, a good EHS software solution can simplify many of these com- plex chemical inventory management tasks and provide more efficient control needed to account for every chemical, at every lo- cation, even down to specific containers.
Fortunately, a good EHS software solution can simplify many chemi- cal inventory management tasks and provide more efficient control needed to account for every chemical, at every location, even down to specific containers.
www.ohsonline.com
MAY 2017 | Occupational Health & Safety 51
Users can store SDSs in online databases specific to their company, providing quick- er access to the critical safety information when needed. Inventory checks become easier with corresponding SDSs at your fin- gertips instead of having to manually locate the documents in three-ring paper binders.
Many of these solutions offer online access to safety data sheets or services to help locate SDSs from manufacturers, and they even offer mobile accessibility, mak- ing access to chemical inventory infor- mation from the field easier. Some of the more sophisticated solutions allow you to track chemicals using smartphone and tablet cameras to scan container barcodes, QR codes, and UPC codes and to use the scanned information to pull up reference data about products in your inventory. In addition to the mobile-optimized func- tionality offered by today’s leading EHS software providers, a handful also feature mobile applications that provide offline accessibility when Internet connectivity is limited or unavailable.
Step Two: Establish Ongoing Training Procedures
One important issue the first GHS train- ing deadline uncovered was that some em- ployees may never have received adequate HazCom training in the first place or had been trained so long ago that they hadn’t retained a basic understanding of the stan- dard in order to be able to put the GHS modifications into context. As a result, the first GHS training deadline not only served to provide workers with information about the new GHS-aligned SDS and shipped-la- bel formats, but also supplied a much need- ed refresher course on HazCom in general.
While OSHA does not require employee training to be performed at a specified in- terval, regular training—even annual train- ing—is a best practice that will help ensure your employees retain critical HazCom in- formation. OSHA, however, does stipulate that training must occur when a new em- ployee is hired. They must be trained to un- derstand the hazards associated with both the chemicals they will be interacting with
and those they may potentially be exposed to in the course of their work day.
Similarly, if a new chemical is introduced into your facility, employees who might come into contact with that substance must be trained on its potential hazards, as well. Again, a comprehensive EHS software solu- tion can streamline the administrative tasks of implementing and tracking employee training. Many include features that not only help you track your training needs and streamline communication to employees about completion deadlines, but some also provide access to a wide variety of on-de- mand safety courses to help you meet your compliance requirements.
Regular safety trainings also will be- come useful as OSHA continues to modify its HazCom Standard with updated ver- sions of GHS. Not only will employees already have a strong knowledge founda- tion of the current rule to understand any changes, but they will most likely be more receptive to the new information with ex- isting—and expected—training proce- dures already in place.
Step Three: Update Your Labels
Consistency in the labeling of hazardous chemicals is a fundamental element of GHS adoption. The GHS-aligned HazCom standard outlines six specific elements re- quired to appear on manufacturer shipped container labels. They are: product iden- tifier, signal word, hazard statement(s), precautionary statement(s), pictogram(s), and supplier information. However, when it comes to workplace labels, compliance is performance-based. This means compli- ance will be determined by how well the la- bels perform during an OSHA inspection.
To assist employers, OSHA essentially outlined three main approaches employ- ers can take when it comes to workplace labeling (also called secondary container labeling). One, employers may continue to use their current compliant workplace labeling systems—so long as the informa- tion accounts for and doesn’t conflict with the new GHS information. Two, employ- ers may use a homegrown system that uses