To this end, the GHS calls for the consistent classification and labeling of chemicals by using a standard set of pictograms, signal words, and hazard warnings.
Chemical Label Changes

The current OSHA Hazard Communications standard (HCS) places a performance-based requirement on chemical labels. Essentially, so long as a labeling system works to mitigate potential accidents, it meets the standard.

Under GHS, regulations will move to a standards-based approach. That means that certain label elements, including hazard symbols (or pictograms), signal words, and hazard statements will be assigned to a given hazard category. The goal is to make chemical data presentation consistent and more easily comprehensible with particular attention devoted to the use of symbols to convey the nature and severity of hazards.

What’s in a Name?
Of course, a major part of the implementation of GHS will be in training personnel in the proper interpretation of a new labeling system.

In terms of nomenclature, under the GHS a signal word means an indication for a reader of the relative severity level of a hazard. Under the GHS, these are “Danger” and “Warning”, the former being the more severe.

A hazard statement under the GHS refers to a phrase assigned to a hazard class and category to describe the nature of the hazards of a chemical product, including, where applicable, the degree of hazard.

A precautionary statement here refers to a phrase that describes recommended measures to minimize or prevent adverse effects from exposure.

A pictogram means a graphic design that includes a symbol and other elements, including a border and a background pattern or color intended to convey specific information.

The present international pictograms to represent the concept of toxicity, for example, are far from standardized and illustrate the potential for confusion that GHS seeks to dispel. In South America, toxicity is represented by a skull and crossbones over a red background framed by a diamond shape and printed with the word “poison”. In Australia, the skull and crossbones symbol is labeled with the word “toxic” and set against a brown background framed by a square. In Africa, the skull and crossbones symbol appears over a yellow background framed by a triangle.

Under the GHS, all hazard pictograms will be in the shape of a square, while all the international variations of symbols used in pictograms will be reduced to just nine. Under the GHS, they are: flame (flammables), flame over circle (oxidizers), exploding bomb (explosives, self reactives), corrosion (corrosives), gas cylinder (gases under pressure), skull and crossbones (acute toxicity), exclamation point (irritants, narcotic effects), environment (aquatic toxicity), and health hazard (carcinogen, mutagen, target organ toxicity).

Moving Forward
OSHA announced in March that the revised standard will be fully implemented by 2016, while Dec. 1, 2013 is the date by which employers are required to train employees on the new label elements and the new safety data sheet format. Compliance with the rule is expected by June 1, 2015, with some exceptions.

During the transition phase, every existing label for shipped containers must be reprocessed to include the new pictograms, signal words, hazard statements and precautionary statements, each placed in a designated part of the label. However, employers may continue to use their own labeling systems in the workplace.

This has been part 2 of a series on GHS. See next month’s issue for information on the new labeling requirements and using the new universal Material Safety Data Sheets (MSDS).

The GHS grew out of the Hazard Communication Standard (Title 29, Code of Federal Regulations (CFR) 1910.1200), also known as the Right-to-Know Law, that took effect in the United States in mid 1980s. The purpose of the HCS standard is to ensure that chemical hazards in the workplace are identified and evaluated and that necessary aspects of these hazards are communicated to employers and employees.

Unlike HCS, the GHS is not a regulation or a standard, but it does establish agreed hazard classification and communication provisions and guidance on how to apply them.

For example, existing definitions of combustibility vary even among agencies in the United States. According to OSHA HCS, for instance, a substance may be deemed combustible when it reaches 100 degrees Fahrenheit, while for the Department of Transportation (DOT), combustibility begins at 140 degrees. When the provisions of the GHS are applied, there will be a single, agreed upon definition.

The ramifications are profound: fewer accidents, improved safety for workers and for the public, and far less need for testing and evaluation to determine proper classifications.
This has been part 1 of a three-part series on GHS. See our next blog for more information on this far-reaching topic.

One way is to understand how to be compliant with the OSHA regulations that apply to your business. Toward that goal, periodic-self inspections or self-audits are recommended by OSHA to help identify any violations and allow for corrective measures to be implemented.
Given the sheer number of OSHA requirements, however, being in compliance can be a daunting proposition for any business, large or small.

Some of the areas to examine during a periodic self-inspection or self-audit at a manufacturing plant, for example, include:

• safety and health program
• personal protective equipment
• flammable and combustible materials
• hand and portable powered tools
• lockout/tagout procedures
• confined spaces procedures
• electrical walking-working surfaces
• hazard communication

We at Workplace Safety stand ready to help keep businesses safe for their employees, for their vendors and for their customers. Toward that end, WPS offers a low-cost, general audit that provides a general idea of where any company stands in terms of compliance with applicable OSHA standards.

In addition to identifying existing concerns, such self-inspections, can also address any past instances of accidents or injuries, which can be examined in order to take possible preventive measures. This, in turn, will cut down on the likelihood of being cited for violations during OSHA audits. And it’s important to keep in mind that, in general, an employer who takes proactive action to try to keep to OSHA-mandated requirements fares much better during an OSHA inspection.

A WPS general audit is a pre-emptive measure, one that can directly impact the health and safety of any workplace. Unlike OSHA-mandated corrective measures following an audit or inspection, there is no obligation to implement WPS’ recommendations. If followed, however, these recommendations will help to cut down on the likelihood of OSHA-cited problems later.

Not returning a call, especially after more than one message has been left, sends a big message: “We’re not interested in your business.” If you’ve ever contacted a company you wish to do business with and been given the cold shoulder, you know the situation.

And given that bad news travels fast, especially with the technology that enables social media, a bad reputation for customer service precedes itself. Most customers have plenty of options to consider. Often, a prospective customer will simply lose interest when presented with unnecessary hurdles.

In Dale Carnegie’s landmark book “How to Win Friends and Influence People”, playing hard to get is never mentioned as a way of achieving either goal. A company’s ethos, or the image it wishes to convey to the world at large, is something that is too often considered as an afterthought. Business relationships that last must work both ways, and some end before they have a chance to begin. No matter how rare or essential the product or service your business provides, not everyone may be beating a path to your door, especially if your business sends a message of indifference.

Not only is returning messages common courtesy, it makes good business sense. At Workplace Safety, we make every effort to return messages as soon as possible, whether they are from existing or prospective clients. We pride ourselves in this common courtesy.

To make your business stand out from the competition, it’s essential to be friendly and communicative with the caller. Make yourself easy to reach and when leaving messages of your own, make them friendly and intelligible. Return calls within 24 hours, if possible. If you haven’t heard back, be politely persistent by following up and ask if the customer or client needs anything else.

Good communication can make the difference in converting an unsure caller into a client or customer. Business relationships that last are two way streets. Make sure your business is headed in the right direction.