Page 36 - Occupational Health & Safety, January/February 2020

CHEMICAL SAFETY/SDS
cides, cosmetics and drugs for personal consumption (FDA); food (USDA); consumer products (CPSC); and chemicals regulated under the Toxic Substances Control Act, which is administered by the EPA.
HMIS & NFPA vs. GHS labels: Which Should I Use?
GHS chemical labels are still fairly new, having only been adopted by OSHA as part of the updated HCS in 2012. Not to mention the grace period for businesses to fully convert to GHS is short, and they must do so by 2016. It makes sense that many ask the question of whether or not to continue to use the previous voluntary work- place labeling systems or move to GHS.
Since 1994, the most prevalent voluntary workplace HazCom labeling systems have been the Hazardous Materials Identifica- tion System (HMIS) and the National Fire Protection Association (NFPA). From the outside, reluctance to switch to GHS may seem purely due to the time, money and other resources required to re- place old labels.
While resources definitely play an important role in HazCom labeling, there is a strong case for “sticking with what you know.” Workers who have been trained on HMIS and NFPA are more comfortable with those systems and may find GHS HazCom labels confusing. Many employers just want to know: Can you still use HMIS and NFPA labels?
The official answer from OSHA, found on osha.gov states, “Yes, OSHA will continue to allow NFPA and/or HMIS rating systems
on labels and SDSs as supplemental information. However, the rules for labeling and placement on the SDSs still apply.”
OSHA’s official answer goes on to explain that the current reg- ulations allow for the use of existing labeling systems like HMIS and NFPA (based on HCS 1994) as long as they are consistent with the current requirements of the HCS. Additionally, supple- mental labels can only be used for chemicals on-site within the facility and employees must understand the specific physical and health hazards.
However, there are three reasons employers should strongly consider moving to the use of labels that are fully GHS compliant:
1. Shipments of new chemicals coming into the facility will have fully compliant GHS labels. If HMIS/NFPA labels are used for workplace secondary containers, then employees need to be trained on both systems. Therefore, moving to GHS-compliant HazCom labels streamlines training into one system.
2. OSHA regulation 1910.1200(f)(6)(ii) outlines the informa- tion required on hazardous chemical labels, which includes physical and health hazards. These are standard elements required for GHS- compliant labels, yet not typically found on HMIS or NFPA labels When an HMIS or NFPA label is used instead of a GHS label, em- ployers must prove employees understand the hazards as well as they would have with a GHS label.
3. The numbering system for HMIS and NFPA are the opposite of GHS. One is the most serious hazard rating for GHS and the least serious for both HMIS and NFPA. While the numbers are not dis-
Circle 7 on card.
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