June 1, 2013 - No
need to panic, at least not yet. But let me remind you that the deadline for
training all employees on the changes brought about by OSHA’s adoption of the
Globally Harmonized System of Classification and Labeling of Chemicals (GHS)
into the Hazard Communication standard is getting closer by the day. And while
the December 1, 2013 deadline for getting all mandatory employee training
completed may seem a long way off, just remember that it was more than fourteen
(14) months ago that the revised OSHA Haz-Com standard was published and the
deadline was first announced!
One of the best ways to understand a new (or revised) OSHA
standard, I believe, is to prepare to teach a class about the topic. I am
already covering this topic when conducting OSHA 10 and 30 hour Outreach
training classes. And I just produced and posted on our website a free online
GHS training tutorial titled “Understanding the GHS Labeling System” for
employers to use for employee training purposes, and am currently working on
the companion course on understanding safety data sheets (will be ready soon).
And many of you already know that I create and post one free toolbox talk each
month on our website related to the GHS training requirements; my goal is to
have twelve (12) free GHS-related toolbox talks posted by December 1, 2013 that
employers can utilize for employee training. As a result of these efforts, I
have come to have a much better understanding of the revised OSHA Haz-Com
standard.
When researching the labeling requirements of the GHS
system, you will note the requirement that one of two “Signal Words” must
appear on all container labels and safety data sheets (SDS’s) for harmful
chemicals and products; either “DANGER” or “WARNING”. For many employees (and
employers), these two terms may seem to be interchangeable, but once you dig
into the standard and its appendices, you can see there is a distinct
difference between their use and intent. In a nutshell, the signal . . .
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