Don’t view the conclusion of this round of GHS deadlines as the end of the process, but rather the beginning of the new state of HazCom and what OSHA now expects for compliance.
Following a decade-long effort, the final effective completion date to align OSHA’s Hazard Communication Standard (HazCom) with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) has come and gone. While companies covered by HazCom may see the conclusion of the GHS deadlines as an ending, it’s critical that they view the changes enacted with GHS alignment as just the beginning. Moving forward, OSHA will not only continue to enforce the current GHS modifications to its HazCom Standard, but the agency has also expressed intent to review and possibly update the rule in the future to align with newer versions of the GHS.
Is your facility fully GHS aligned and prepared for any future GHS-related modifications to the HazCom Standard? Following are the key steps you should perform now, not only to safeguard employees from hazardous chemical dangers, but also to ensure your facility remains in compliance.
Step One: Organize Your Chemical Inventory
Having an accurate chemical inventory creates the foundation for effective chemical management initiatives and is a key building block to ensuring compliance with GHS updates to HazCom. Without a true understanding of what chemicals you have and where they are, it’s impossible to know what products should be on your radar and accounted for in your hazardous chemical management, reporting, and compliance strategy. As part of your overall strategy, ensuring an updated inventory will allow you to more easily identify chemicals that are missing their corresponding safety data sheets (SDSs) or have out-of-date versions that should be replaced.
A good first step is to follow the chemical inventory list located in your written HazCom program (in the event that you don’t have a chemical inventory list in your written plan, now is the time to do this because it’s a mandatory component of a compliant OSHA HazCom program). Take your time walking through the facility, noting any inconsistencies with chemicals, locations, or amounts. Make sure the chemical manufacturers’ names, addresses, and telephone numbers line up with what is recorded on the inventory list and SDS; this will be key if you need to contact them for any updated documentation.