GHS The Final Countdown: Common Misconceptions About Compliance

It’s been a long road to compliance; the updated Hazard Communication Standard (GHS) process officially started in 2009 and is set to wrap up this June 2016. A fully compliant GHS facility will bring with it improved quality and consistency of hazard information provided throughout the workplace, better comprehension for workers, quicker and more efficient access to SDS for workers, and a ton of money saved across industries.

With that being said some safety managers are still having trouble understanding a couple of areas of GHS that perhaps aren’t as cut and dry.  Read on to get some clarity on these lingering misconceptions in GHS compliance.

Q: The containers within my facility vary in size and some of them are tiny, what is the minimum required information for small bottle GHS labeling?

A: There has been some debate on the minimum required information for small bottles. Initially, OSHA stated that labels must include all the required information. If the container is too small to print everything legibly on the label, then an extended content label would be necessary.

Added cost will not be an acceptable excuse for noncompliance.

There has been recent discussion that the following is the minimum you’re required to print on the small labels.

• Product identifier • Appropriate pictograms • Manufacturer’s name and phone number • Signal word • A statement indicating the full label information for the chemical

This might mean you can avoid the added cost of an extended content label.

Q: If there are 3 red squares on a label but I only need two pictograms can I keep the third one blank?

A: No. You either need to use a label template with the exact number of pictogram diamonds you’ll need or you’ll need to completely black out the unnecessary pictogram with black ink. If you’re printing your labels on-demand with a Brady Printer, this will not be an issue. Be advised that if a blank red frame is not fully covered and filled in, the label will not be in compliance.

Q: What is the major change between old HazCom Labeling and New GHS labeling?

A: The Old Hazcom standard was not universal and all business had their own system. Under the New GHS Standard all chemical manufacturers and importers are required to provide a universal GHS labels that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.

Q: Are any chemicals exempt from the GHS regulation?

A: No. GHS covers all hazardous chemicals. There are no complete exemptions from the scope of GHS for a particular type of chemical or product. The term “chemical” is used broadly to include substances, products, mixtures, preparations, or any other terms that may be used by existing systems. The goal of the GHS is to identify the intrinsic hazards of chemical substances and mixtures and to convey hazard information about these hazards.

For more information on the GHS regulations, click here.