USA GHS/OSHA labeling

Howdy all,

In the USA come June 1, 2016, increased labeling requirements for materials stored on the company site go into effect.

Anyone have down-to-earth plans to handle this challenge?

AFAIK, there is not yet a small container exemption in place...

Interested in how others are tackling this.

 

Not much is changing in our practice. We just re-checked or requested all of our safety data sheets for updated versions. Even as of current, some of our chemicals' manufacturers do not yet have SDS's which conform to the new 16-section format, but after exhausting our options all we can do is accept the fact that it is outside our realm of control and keep records that show we are at least demonstrating good faith in our diligence.

With manufacturer's labels, each chemical container is checked for legibility and visibility of hazard information. Secondary (portable) containers used for transferring liquids are fitted with a standard NFPA 704 label with basic hazard information included on the label. In our case, about a third of the people are using common household chemicals for product cleaning so the hazards are easily manageable. All label checks occur during our quarterly safety inspections.

Our safety bulletin boards also contain a detailed explanation of the NFPA diamond and how to interpret it. This information is also communicated and reinforced through periodic GHS training with the staff as outlined in our training plan. On top of that, we select employees at random for questioning on various health & safety topics. The selection is based on a representative sample of the population (according to area) and also occurs during our quarterly safety inspections.

And I am about to review our HazCom plan once again for updates. The biggest impact to us right now will be making sure our chemical inventory lists and SDS's are up-to-date, since any changes from them may affect the labeling requirements for our secondary containers.

 

Thanks Brian,

Do you move material from the vendor's container to another container?
I work at a formula based manufacturer...so the vendor container is stored with the existing label...but then some of the material is dispensed for use.

It is the labeling of the second and subsequent containers that I am wondering about...they also have to have hazcom labels unless the new container "is only intended for immediate use by the employee who performs the transfer".

Applying this to baking (a formula based process)...the mixing bowl, cake pan and cooling rack would all need hazcom compliant labels for the mixture (pictograms, H&P codes, signal word, etc.) when they contain the mixture.

 

Yes, we do transfer certain chemicals to smaller secondary containers for extended use at workstations. If the amount used is in excess of one workstation’s operational supply we leave it in the manufacturer's container and store it in a designated flammable materials storage (FMS) cabinet (which is locked). As far as our secondary containers go, we just add the NFPA labels to all of them that we could find. Since all of our secondary containers look alike, labeling them was an easy task - I have attached a sample label that I created to illustrate. If for some reason the hazard information on the SDS changes, we can update the label accordingly. If our safety inspection reveals an unlabeled container, we either attach the appropriate label to it or keep it in the FMS cabinet, to prevent improper transferring of chemicals within the plant.

The main requirements that we focus on are that all secondary containers not intended for "immediate use" must contain an appropriate label that remains firmly attached and legible, and which contains general information on the hazards of the chemical. More importantly, we need to ensure that all exposed employees know how to read the label and use the information it conveys to protect themselves.

Also keep in mind that OSHA defines the term "immediate use" as meaning "that the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred". The secondary containers I described above are not intended for immediate use (they are kept at the workstations and used by others until they are ready to be refilled), so we label them. Bottom line: If your secondary container does not meet the criteria for immediate use, your best bet would be to label it and move on.

 

Hi Brian,

Thanks for your input.
At least from your sample label attached...it looks like we are in two different worlds.

At any given time, there may be materials in process at the end of the shift...and floor storage of raw materials not yet used. Our raw material count is just about 3000 unique items...a few hundred of which may change "container" in a day, either by dispense for future use, combination as part of a manufacturing process, manufacturing process WIP inventory point, or reaction of multiple materials to form a new material.

A design of experiments can generate 60 containers, each 'fairly unique', for a single person in a single day.
Without the DOE, just normal life, I would estimate 30-50 new "containers" per day...every one with a different material.
I'm just trying to wrap my head around how to remain compliant. pre-printed labels just don't work for us, there are too many different ones.

 

Ah I see....yes your operation does look like a whole other beast.

Then the answer to your dilemma may reside in this OSHA regulation:

 

Yup...and that was what I was asking about...ways that folks plan to use in their shops to be not only in compliance with f7...but also to have things simple enough that folks actually understand the hazards.

One scenario that comes to mind is to put a phone book sized list of everything in several places...it would be compliant with the letter, but hardly filling the intent of the new regs.

 

I would not stop there. To effectively meet the intent, your alternative method would also require supplemental controls which provide workers with an "immediate visual reminder" of hazards, which is why signs and labels are so valuable.

For example, if your approach was to put every SDS into a book and place several of these books at working locations, this would not meet the intent as SDS's by themselves do not constitute an "immediate visual reminder" of the hazards associated with exposure to a specific chemical or composition. Almost any CSHO will spot this right away and issue you a citation, even if you have a stellar training program in place and everyone understands their specific materials. I'm sure that whatever you come up with will need to be homegrown and custom-tailored to your operations.

I don't have much else to add here, but you might want to consider pull-out labels or tags as an alternative method of communication.

 

Six months away...anyone else deep into this labeling transition? Or am I the only multi-chemical handler here?

 

Now two months away .... and really surprised to not see other threads about this.

Is no one else here handling chemicals that fall under OSHA 29 CFR.... like floor wax and window cleaner?