What manufacturers need to know about GHS compliance

By Andy Scherz, Senior Product Manager, Epson America in Pharmaceutical Packaging on December 11, 2013

 

The North American chemical market is in the midst of a major regulatory shift. On Dec. 1, 2013, this transition has impacted more than 43 million employees in the United States, including chemical manufacturers, distributors, exporters and suppliers. To develop a safer, more efficient approach to the international shipment and transport of chemicals, the Occupational Safety and Health Administration (OSHA) has set forth new guidelines designed to standardize how chemical and hazardous information is communicated in manufacturing facilities and other workplaces. This framework is known as the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals.

 

As a global leader in chemicals manufacturing and exports, the United States accounts for 15 percent of global chemical shipments, exporting $80 billion annually. This is not only one of the top drivers for the country's manufacturing sector but a major catalyst for the expansion of global commerce. One challenge that has accompanied this growth is the diverse method for classifying and labeling chemical products employed by different countries. The United Nations originally designed GHS as a universal set of guidelines that countries could follow to eliminate this confusion. Prior to the onset of international adoption, these differences proved expensive to regulate, led to costly shipping errors and, most importantly, posed an unnecessary risk to employees who were unable to interpret chemical hazards accurately.

 

Internationally, various agencies and nations (such as Europe, Australia and Japan) have already begun implementing GHS standards into their regulatory structures. OSHA originally adopted the GHS standards into its revised Hazard Communication Standard (HCS) in March 2012. Beginning with the first critical deadline on Dec. 1, this revised HCS consists of four target dates requiring manufacturers to be fully compliant with all employee training, classification and labeling of new chemical standards by June 2015.

 

Despite the global focus on GHS, understanding exactly what these new standards mean may be a daunting task for companies that are unaware of the requirements. The purpose of adopting these revised standards is to increase workplace safety, standardize products internationally and increase productivity. Labeling is a central part of this new standard; manufacturers will need to incorporate new symbols and color requirements into their chemical label production. The following article will provide companies with an understanding of these new guidelines and what tools they need to efficiently and cost-effectively produce GHS-compliant labels, avoid adoption hurdles and realize operational benefits sooner.

 

Industries impacted
OSHA estimates that more than five million workplaces in the U.S. are impacted by GHS guidelines. These standards are applicable to any industry where employees are potentially exposed to hazardous chemicals including consumer-centric companies where common chemicals are present (such as cleaning supplies, pesticides and pharmaceuticals). This will primarily impact chemical manufacturers, distributors and importers that comprise approximately 90,000 facilities and three million employees nationwide. OSHA is the primary regulatory agency committed to overseeing GHS adoption but several other U.S. agencies-including the Environmental Protection Agency, Department of Transportation (DOT) and Consumer Product Safety Commission-will play a role in oversight.

 

GHS-specific changes
There are four major changes related to GHS: hazard classification, labels, safety data sheets (SDS) and employee training. The new measures require chemicals to be reclassified under the specific conditions in which they pose physical, health and environmental hazards. The GHS standard requires manufacturers to consider the full range of available scientific data when classifying chemicals. Additionally, under this new classification, the hazards a chemical presents are further divided by severity. Chemicals with the greatest severity are given the lowest numerical value (that is, a "1" category is the worst). The benefits associated with these revisions ensure that hazard evaluations are more accurate and consistent regardless of manufacturer, supplier or even country.

 

SDS's are currently referred to as material safety data sheets (MSDS). These documents provide comprehensive product information for use in the workplace. Under GHS, SDS's will present product information under a new 16 section format. Primary information (such as first-aid measures) is presented at the beginning of the SDS, with technical information following afterwards. In addition to a change in the sequence of information, section two of the SDS will contain comprehensive hazard information found on the product label.

 

 

GHS label

 

 

Labels are a key facet of the new GHS standards. Beyond the new requirements, manufacturers must train employees on the new visual elements (such as pictograms and color requirements) and incorporate color printing into their operations. Prior to GHS, labeling formats for the same product could vary based on diverse regulatory requirements and applications. Currently, label preparers need only provide the identity of the chemical, any corresponding hazard warnings and the contact information of the responsible party with no uniform format required. This confusion led to operational costs associated with managing multiple labeling systems and large inventories, shipping errors and reduced productivity.

 

The new GHS label structure provides a standardized indication of hazard classes and categories. These new requirements include a product identifier, harmonized signal word, pictogram, hazard statement, precautionary statement and supplier contact information. Furthermore, HCS adoption of GHS label requirements only applies to the classification and labeling of chemicals in the workplace. While workplace labels are parallel to shipping labels in format and criteria, these requirements are regulated by the DOT.

 

GHS pictograms convey health, physical and environmental information associated with a specific hazard class and category. Each of these pictograms includes a different hazard symbol on a white background with a red square frame set on a point. While there are nine pictograms under GHS guidelines, the revised HCS only requires eight (the environment pictogram which pertains to aquatic toxicity is non-mandatory).

 

Harmonized signal words in the GHS system are meant to communicate a product's level of hazard. On GHS-compliant labels, manufacturers must indicate either "warning" or "danger" to demonstrate this properly ("danger" indicates a product's hazard is more severe).

 

Another major shift in label production is the requirement to print labels in color. Under the revised guidelines, pictograms must be printed with red borders. OSHA permits manufacturers to produce labels via color printing or pre-printed color labels. Despite these options however, the use of pre-printed color labels can result in incomplete label applications where chemical products display empty frames. This is not acceptable as a GHS-compliant label and can result in worker confusion and create inconsistency with DOT label regulations. Pre-printed color labels can also add expenses such as inventory management and supply storage.

 

British Standard BS 5609 is another key GHS requirement that takes into account the widening global trade landscape. For overseas transport of chemicals, BS 5609 requires that printed labels survive three months of salt water submersion while maintaining print and adhesive integrity.

 

Critical deadlines
The first critical deadline for GHS adoption was Dec. 1, 2013. By this date, OSHA required that all employees handling or exposed to hazardous chemicals be trained on new GHS label elements and SDS formatting. Since many companies abroad and domestically have already begun shipping products using the new GHS-compliant labeling requirements, the training deadline has been prioritized to familiarize employees with the GHS label formats and minimize any confusion over the new label structure.

 

The next major phase for GHS essentially asks companies to become fully compliant with all the new provisions. This June 15, 2015, deadline requires complete reclassification of chemicals, integration of new label requirements and GHS-formatted SDS's. One exception to this phase is the six-month grace period (Dec. 1, 2015) distributors are given to ship any products that are still labeled under the old system.

 

June 1, 2016 marks the final major deadline of GHS integration. By this date, employers must have updated their hazard communications plans as necessary to reflect any updates to label, SDS and employee training requirements stemming from newly identified physical or health hazards.

 

On-demand color labeling as a solution
The multi-faceted requirements for GHS adoption can present several challenges for companies, especially smaller businesses that must still adhere to the new guidelines. OSHA estimates the annual costs associated with upgrading label printing equipment and supplies at approximately $24.1 million annually. Using tools like Epson's on-demand color labeling technology, manufacturers can defuse the cost of pre-print label inventories and transition to GHS compliance effectively.

 

Additionally, Epson labels are chemical and water-resistant meeting BS 5690 certification- when printing on approved synthetic material-ensuring that labels do not degrade, smudge or fade. Epson's on-demand color labeling solutions provide a simple approach to GHS label compliance, printing accurate labels as needed regardless of a product's hazard information.

 

For manufacturers integrating printing services into their operations, seeing faster benefits come from GHS standards means having a flexible system that can print durable, full color labels and diverse product information and label sizes on demand. Epson's single-step process reduces inventory of labels to blank stock, minimizes the risk of labeling errors and provides the flexibility to print out the precise GHS-compliant format and quantity desired while eliminating any concerns over printing incomplete labels.

 

Source: Epson America Inc.

 

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The manufacturer deadline is June 1, 2015, not June 15, 2015.