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Eric Stager
Eric Stager, CIH, CSP has over 20 years of experience as an EHS professional in the areas of industrial hygiene, safety management, auditing and EHS training. Prior to joining TRC, Eric worked in the pharmaceutical and chemical industries, as well as at a regional EHS consulting firm. Eric is a Certified Safety Professional and Certified Industrial Hygienist by examination. He currently serves as the Region VIII Vice President and as a member of the Board of Directors for the American Society of Safety Engineers.

E: EStager@trcsolutions.com
Q: What is Global Harmonized System (GHS)?
A: The new Global Harmonized System (GHS) revises several areas of your company’s hazard communication program. First, material safety data sheets (MSDS) have been renamed safety data sheets (SDS) and companies are now required us the 16 part format as per ANSI Z 400.1 or equivalent. More information is required under this format which encompasses all health and safety information including hazard recognition but also environmental effects, transportation regulations, and waste disposal information.

Second, companies must update their written hazard communication program to reflect the changes in labeling of incoming containers and information that is required on the container labels.



Q: How does the Global Harmonized System affect my company’s hazard communication program?
A: This revision is the first since 1985 and will dramatically revise how we classify human health and physical hazards through the use of new criteria. Companies will need to classify substances and/or products to ensure that the appropriate classifications are assigned. Companies will also need to revisit how their safety data sheets (SDS) are arranged with new information being required and updated labeling. The labels will require the use of pictograms. Training will be required for all companies on the new Hazcom requirements.


Q: What changes were made, how does this alter existing labeling, and what the most important things I need to know?
A: Material Safety Data Sheets (MSDS) have dropped material from its name and are now called Safety Data Sheets (SDS). The sheets have been re-organized into a 16 part format that follows the ANSI Z400.1 standard or a similar format. OSHA cannot mandate some information on the sheet as it is outside their authority like environmental effects, waste management, and transportation, but other countries require this information so it will be necessary for products shipped outside the United States.

Q: What are some of the challenges or sticky points I need to know about this change?
A: The new pictograms and numbering system are different from the NFPA 704 Diamond and the Hazardous Materials Identification System (HMIS) color bar system that has been used in the past that this new pictogram looks at more hazards and the numbers used are dramatically different.

Q: What the timeline of implementation?
A: OSHA has a phase timeline of implementation with training being completed on the new requirements of the standard by December 1, 2013. By June 1, 2015, all manufacturers and distributors must comply with all the new /modified provisions except that distributors have until December 1, 2015 to provide revised labels for all the products shipped. OSHA will begin full enforcement on June 1, 2016 including updated labels, hazard communication program, and continue to provide additional training for workers on newly identified physical and/or health hazards. This means that during the transition period, employers can comply with old or new standard as far as labels and SDSs.
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