What are the NEW regulations?

• OSHA has adopted new hazardous chemical labeling requirements as a part of its recent revision of that Hazard Communication Standard, bringing it into alignment with the UN’s GHS (Globally Harmonized System) for hazard communication
• By June 1, 2016 companies must be fully compliant of GHS, meaning that employers must:
  •  Update alternative workplace labeling
  •  Provide hazard communication program as necessary, and
  •  provide additional employee training for newly identified physical or health hazards.
• Label requirements for a hazardous chemicals must contain:
  • Name, Address and Telephone Number – of chemical manufacturer/importer/other responsible party
  • Product Identifier – How chemical is identified either by name/code number/batch number and must be the same on both the label and in section 1 of the SDS
  • Signal Word – Indicates the severity of potential hazard, either using “Danger” or “Warning”
  • Hazard Statement(s) – Describes nature of chemical hazard(s) or the degree of hazard, specific to classification categories, and chemical users should always see the same statement for the same hazards no matter what the chemical is or who produces it. (i.e. “causes damage to kidneys through repeated exposure when absorbed through skin”)
  • Precautionary Statement(s): Describes recommended measures to minimize/prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling. There are 4 types:
    • Prevention – to minimize exposure
    • Response – in case of accidental spillage or exposure, emergency response and first aid
    • Storage
    • Disposal

• Pictogram(s) as pictured here: Nine Graphic symbols used to communicate specific info on chemical

Health Hazard ·          Carcinogen·          Mutagenicity ·          Reproductive Toxicity ·          Respiratory Sensitizer ·          Target Organ Toxicity ·         Aspiration Toxicity	Flame ·         Flammable·         Pyrophorics ·         Self-Heating ·         Emits Flammable Gas ·         Self Reactive ·         Organic Peroxides	Exclamation Mark ·         Irritant (skin and eye)·         Skin Sensitizer ·         Acute Toxicity (Harmful) ·         Narcotic Effects ·         Respiratory Tract Irritant
Gas Cylinder · Gases under Pressure	Corrosion ·         Skin Corrosion/Burns ·         Eye Damage ·         Corrosive to Metals	Exploding Bomb ·         Explosives ·         Self-Reactives ·         Organic Peroxides
Flame Over Circle   ·         Oxidizers	Environment (Non-Mandatory) ·         Aquatic Toxicity	Skull and Crossbones ·         Acute Toxicity (fatal/toxic)

How to follow new regulations and NOT get fined

• Get with the program and ensure that as chemical manufacturers, distributors and end users, we are compliant with GHS labeling, effective since June 1^st, 2016.
• It is reported that the maximum fine was expected to rise from $7,000 per violation to $12,600 per violation, and for more serious issues from $70,000 to $127,000 per violation.

What are the biggest challenges to comply?

• Obtaining new Safety Data Sheets (SDS’s) that are GHS-compliant from vendors, which directly affects the ability to produce secondary container labels (required as of June 1^st, 2016).
• Time to fully understand and complete changes to reach compliance and ability to train staff.
• Authoring and distributing new SDS’s and finding a sufficient GHS labeling solution and/or provider.
  • Here’s a Solution made easy!
    • Avery has GHS labels now available that are industrial grade, specially designed to be chemical and tear-resistant, along with FREE label-printing software, available from Avery’s website (Since it operates from the website, no download is required and GHS labels can securely be saved online or to a computer).
    • It allows you create and print your own GHS labels from pre-designed templates and includes the pictograms and GHS compliant statements needed for appropriate GHS labels. This includes customizable text, insertion of a company logo, types of barcodes, or other variable data.
    • So, if you enter the CAS number from the SDS, the software fills these in and allows you to modify them to suit your labels. Avery labels are modifiable to fit full range of sizes to fit drums, totes, pails, can, jugs, and small bottles.

Why the new changes? What are the benefits?

• Mainly for hazard classification and communication. This is a good thing since it will help chemical manufacturers to further improve safety, protection and health for workers, by expecting to prevent injuries and illnesses.
• It cuts out the complexity and makes production safer.
• Becoming GHS label compliant will ultimately make passing safety audits easier.
• It helps to clearly display chemical data, to ensure preventing mistakes of misidentification, along with other important data. It helps with mishandling along the entire supply chain – from manufacturer to end user, both domestically and internationally.  In other words, it is a universal understanding and alignment of regulatory requirements.