Earlier this month, the Occupational Safety and Health Administration released their 2011 semi-annual regulatory agenda. Among one of the regulatory agenda items was the timeline for completion of the Final Rule for the implementation of the Global Harmonization System of Classification and Labeling into the Hazard Communication Standard. According to the agency’s timeline, the Final Rule will be issued sometime in August, 2011. One question that I have is, “After implementation of GHS, will we experience improved chemical safety training and knowledge?” Based on years of experience, I’m still surprised by the lack of knowledge that most employees have regarding chemical safety, and how ineffective are chemical safety training programs.
History of the Hazard Communication Standard
OSHA’s Hazard Communication Standard was first adopted in 1983 for the manufacturing sector, and later, in 1987, OSHA expanded the coverage to all industries where employees have the potential to be exposed to chemical substances. The overall goal of the Hazard Communication Standard was to improve chemical safety and employee awareness of chemical hazards. The Hazard Communication Standard required that all manufacturers and importers of chemical substances to evaluate the hazards of the chemicals that they produce or import. Once the manufacturers have performed their evaluations, they are required to communicate this chemical hazard information to their customers and other users in the form of chemical safety labels and material safety data sheets (MSDS). All employers with chemical substances in the workplace are then required to develop a written hazard communication training programs, ensure proper chemical safety labeling, and provide chemical safety training. Despite the Hazard Communication Standard being in place for over 28 years, according to OSHA, as of October 8th, 2010, it still remains to be one of the top ten most frequently cited OSHA standards.
Will Chemical Safety Training improved with GHS?
Once the Final Rule is adopted, and the implementation goes into effect, several actions will be required. These actions are as follows:
- First, employers will need to ensure that their written hazard communication program is current with the new GHS hazard classifications systems;
- Second, that labeling systems are consistent with the new requirements;
- Third, employee chemical safety training programs will need to be revised; and
- Finally, that all employees receive chemical safety training regarding the new classification systems, labeling, and safety data sheets (SDS).
According to OSHA, the agency expects that the adoption of GHS will improve the comprehensibility of chemical safety information and will result in improved employee protection. I would submit, that improvements in the understanding of the chemical safety information will only occur it employers improve their chemical safety training and the methodology that it is delivered. Simply changing the appearance of labels, and adding a more complex classification system will do little to improve safety without improvements in chemical safety training. Despite the availability of many eLearning systems, most chemical safety training is still done via the old fashion slide presentation way.
Affygility Solutions will be closely following the implementation of GHS. In early September, we will offer a 2-hour webinar on the revised Hazardous Communication Standard and GHS. If you have any questions, please contact us.