The Globally Harmonized System for Classification and Labeling of Chemicals (GHS) has many inherent benefits for companies at all stages of chemical production. Including reduced fatalities and millions of dollars in savings, the perks of the standard are directly dependent on the cohesive system for displaying hazards on both SDS sheets and GHS hazard labels.
Many companies are confused about the label standard – understandably so. The actual GHS, also known as the “Purple Book,” offers very little information beyond the required label elements, which you can find a description of here. However, the requirements for carrying the label standard out are left incredibly vague.
Looking at the OSHA guidelines for inspection is perhaps the best way to explain how your company should approach labeling.
OSHA provides the following in their Small Entity Compliance Guide for Employers That Use Hazardous Chemicals: “If your workplace is inspected by OSHA, CSHOs will be looking for at least the following aspects of your labeling approach:
- Designation of person(s) responsible for ensuring compliant labeling of shipped and in-plant containers;
- Description of written alternatives to labeling of stationary process containers (if used);
- Appropriate labels on all workplace containers, including those received from a supplier, secondary containers, and stationary process containers;
- A description and explanation of labels on both shipped and workplace containers included in the employee training program; and,
- Procedures to review and update workplace label information when necessary”
One of the most important aspects of the OSHA inspection checklist is #2:. You may use alternative methods of labeling for many containers that are too small to fit a full label or those that cannot have an immediate label (for whatever reason).
Included in this provision are signs, placards, process sheets, batch tickets, operating procedures, and any other written material instead of attaching the labels to individual stationary process containers – but only if your company is able to provide a clear description of your methodology, to which containers it applies, and shares general information about the hazards of those chemicals to which the provision applies.
The rest of the list is fairly self-explanatory. Your company must have established standards for labeling for many different aspects of the process, and must be able to present those to OSHA. Your labels must be accurate and appropriate, and you must have a procedure for reviewing them and making sure they are up to date. You must have someone designated responsible for that process, and y have descriptions and explanations of those labels.
Labeling can be a confusing process, but creating these standards will help to guide you through the transition to GHS. If you have not already set up a system to implement GHS hazard labels you should begin ASAP, since hazard labels have the same June 1st, 2015 deadline for GHS compliance.
