OSHA GHS Proposal
OSHA mandated changes to its hazard communication standard (HCS), and aligned itself with the Globally Harmonized System (GHS) in 2012. The first deadline for training employees on the changes passed on December 1, 2013, and was fully implemented on June 1, 2015.
OSHA GHS Overview
Part of these mandated changes dictate that chemical manufacturers and importers are required to prepare Safety Data Sheets (SDS) and Globally Harmonized System (GHS) aligned labels for the chemicals and hazardous materials they ship. This initiative is known as HazCom 2012. As an employer you are responsible for training your employees so they understand GHS labels and know how to find and read the SDS.
GHS labels include more information than the old RTK labels. Previously, when there was a spill or accident, workers had to quickly find and be able to read the MSDS. With GHS labels they have the needed information on the label.
This means that GHS aligned labels are more complex than the old RTK labels and training is critical as well as being required by OSHA. Every employee who works with, or might possibly be exposed to a hazardous substance, must be trained in how to read both the SDS and the GHS label.
The GHS and SDS training deadline was passed on December 1, 2013. GHS labels and SDSs started arriving in your workplace before that. The deadline to transition to full use of HazCom 2012 which includes the use of the GHS aligned labels was June 2015.
The only OSHA statement about the content of the required training is: "OSHA's final rule requires employers to train employees on the new label elements and safety data sheet format."
Are there still free OSHA GHS training materials available?
OSHA has provided a set of three "Quick Cards" for use in GHS training for employees. They are available in both English and Spanish. They are:
Hazard Communication Safety Data Sheets Training
This Quick Card lists the 16 sections of a SDS and gives a brief description of 12 of them. The remaining four categories are not described as they cover information required by other agencies and are not enforced by OSHA.
GHS Label Training
This Quick Card (PDF) provides a sample GHS label and a statement that as of June 1, 2015, all labels will be required to have pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification.
This Quick Card shows the nine pictograms that are used on GHS labels. It shows the pictogram, describes the pictogram with a word or two, and lists the hazards represented by the pictogram.
While the above free OSHA GHS training tools should be sufficient to comply with the OSHA HCS requirement to "train employees on the new label elements and safety data sheet format" additional training on both GHS labels and SDSs should be incorporated with your hazardous chemical training.
Section (h) of the Hazard Communication Standard describes the chemical hazards training employers must provide.
"(h)(1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets."
As a part of the above training on hazardous chemicals, employees should be trained to be familiar with the GHS labels and SDSs they will see on containers holding these hazardous chemicals in your workplace.