Page 56 - Occupational Health & Safety, May 2017

CHEMICAL SAFETY/SDS
If 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 compliant OSHA HazCom program.
a combination of the manufacturer shipped label elements and other information—so long as workers have been trained to com- prehend it and it doesn’t contain any conflicting information. Or, three, simply replicate the manufacturer shipped label.
Replicating the shipped label is considered by many a best prac- tice because it provides greater consistency between the two types of labels employees encounter in the workplace. Employees already should be trained on the GHS-aligned manufacturer shipped label format, so this approach also eliminates the need for additional training on a separate label system and lessens the burden placed an alternative label to perform as effectively as the shipped label. Here again, the leading electronic chemical management systems will in- clude features that can help you easily produce GHS-aligned work- place labels using information taken directly from a product’s SDS.
Whatever approach you take, you should make sure your cur- rent workplace labeling system can perform during an OSHA inspection to indicate that employees have all of the information needed about hazardous chemicals in the workplace, including
those newly identified as a result of GHS adoption.
Step Four: Be Prepared for What May Come Next
While the final GHS deadlines have come and gone, it’s prudent to remain prepared for any additional changes to come. A good industry best practice is to designate a GHS transition leader. Such a person would have a familiarity with both current and po- tentially new GHS requirements and your site-specific GHS tran- sition process and would be able to employ his or her knowledge and experience to drive the implementation of any future GHS changes resulting from OSHA’s adoption of newer editions of the global system.
Most importantly, do not view the conclusion of this round of GHS deadlines as the end of the process, but rather the beginning of the new state of HazCom and what OSHA now expects for com- pliance. With the phased-in period behind us, we’re now closer to what may be the smaller but still significant GHS-related changes to come.
Glenn Trout is president and CEO of VelocityEHS, a cloud software company that helps companies manage SDS/chemical inventories, audits, inspections, incidents, corrective actions, compliance issues and reporting and safety meetings management. For more informa- tion, visit www.EHS.com or call 888-362-2007.
52 Occupational Health & Safety | MAY 2017
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