It’s official. The deadline to implement the Global Harmonized System (GHS) is here. The new regulations have slowly been phased in since they were initially set back in 2015, however now is the time that all employers need to make sure that their program is up to date to meet the December 1st deadline.
I get asked a ton of questions regarding what has changed with GHS, so I wanted to write a quick blog to cover what you need to have in place at your workplace before the deadline:
1. Labeling and Identification
Every container with hazardous material inside must have a GHS label with relevant information. To prepare, your facility should have a way to create GHS labels in the event that the manufacturer label is damaged or you are transferring a material into another container.
By December 1st, you should have a policy written on label creation and training performed for those who will be working with and responsible for hazardous materials. Purchasing a printer and supplies is recommended. One that we use in our facility is the Brady BBP35.
2. Hazardous Container Audit
One of the most-often overlooked issues is that all containers need to be audited to ensure they are in compliance with the new regulations. This means that all containers have updated labels with the appropriate pictograms and warnings. Not only are these important for hazardous materials that are in the manufacturer containers, but are also required if you transfer that material into a smaller container or bottle to perform work with so it may be identified.
The audit process should be completed by November 30th, along with policies on how to manage improperly-labeled containers.
3. Policy Updates
It’s important that you have a written policy that is updated with how and when you perform employee training and deal with labeling procedures. Remember, you are required to perform audits as conditions change within your facility to ensure that workers are clear about the dangers of the hazardous materials they work with and that the proper PPE and warnings are in place for handling these materials.
If no changes are made, you are still required to perform an audit once a year. Your new policy updates are required to be in effect starting December 1st.
For more details, be sure to download out GHS Checklist by filling out the form on the right hand side of this page. This guide gives a great overview on what you need to keep you and your workers safe and compliant.
Have questions? Be sure to give us a call. We’re glad to help you navigate these new changes.