Are you prepared for this?
Managing chemicals at the workplace is often a difficult task. A manufacturing company, for example, may have a few hundred chemicals on site that are used in the production of products. The employer's duty under the Occupational Health and Safety Act to provide information, instruction and supervision to a worker to protect the health or safety of the worker applies to chemical hazards. Employers should inventory what they have on site, coordinate what is being purchased with what is actually being used or what has been replaced, assess the chemical hazards and means to control the hazards, update material safety data sheets (MSDS), and educate and train workers about the chemicals used in their day-to-day tasks.
Learn more about the GHS regulations in the US here »
For a Canadian company supplying chemicals to both the United States and Canada, the challenge will be meeting the criteria of GHS and maintaining the current requirements of WHMIS. Keep in mind that the safety data sheets must contain WHMIS-required content and that a GHS hazard classification may not be the same as the WHMIS classification.
Product labelling remains, but with significant changes. GHS labels will require the new hazard pictograms, signal words such as “danger” or “warning,” hazard statement, precautionary statement, product identifier and supplier identification. The use of standardized hazard statements will replace risk phrases currently used by suppliers. The information on a GHS label will be based on the hazard category and derived from charts in the standard. At this time GHS labels are not accepted in Canada. This may affect your company if chemicals are imported from the United States. WHMIS regulations for labels will apply, including the use of WHMIS symbols, the hatched border, reference to the material safety data sheet, and the data sheet in English and French.
The employers’ duties to train and educate workers in WHMIS do not change when transitioning to GHS. Training programs will need to be revised to accommodate the new pictograms, hazard classes, labeling requirements, the meaning of signal words and hazard statements, and learning the new safety data sheet format. In the United States, Dec. 1, 2015 is the deadline for shipping containers without a GHS label. If an employer is importing chemicals from the United States, the employer should ensure workers are trained and understand the differences of the GHS labels and safety data sheets.
Global companies may already have begun to see safety data sheets or labels from countries in Europe showing the various pictograms, signal words and hazard statements. With the final ruling of OSHA and the timelines dictated to companies to begin the transition to GHS, labels and safety data sheets showing GHS requirements may become more prevalent in Canadian workplaces.
When Canada adopts GHS, it is not anticipated that the current communication system, WHMIS, will disappear, but it may change. For a company operating in several countries, having one standard for chemical labelling and safety data sheets may significantly reduce operating costs, help companies overcome trade barriers and remain competitive.
Implementing GHS in Canada may not only influence an operating cost reduction for companies, but may ultimately reduce the cost of worker compensation claims resulting from workers injured or becoming ill due to chemical hazards in their work environments. The detailed requirement of pictograms, signal words and hazard statements provide various communication methods to a worker expanding their current right to know into understanding.
How will OSHA’s adoption of GHS into their HCS impact Canada? For companies operating in both countries the need to create additional safety data sheets and labels in order to meet the requirements of GHS and WHMIS may be challenging, time consuming and costly. The change may prompt Canada to implement GHS sooner than later. In the meantime, for companies trading with the United States it would be prudent to begin the process of compliance to the requirements for safety data sheets, labelling and worker education and training.
Expectation is that Health Canada will introduce proposed regulations in Canada Gazette I at the end of this federal fiscal year – March 2013.
GHS? Bring it on.
We’re ready, as are our customers. The real question is how can we help you? The transition to GHS is an opportunity for you take your hazardous chemical management to the next level, and we’d love to be your partners in that. ICC Compliance Center is excited to announce a GHS Awareness Training – An Introduction to GHS within Hazcom (US) Web-Based Training course (Be sure to click on the “webinars tab”).
Most importantly, why choose ICC for your GHS training? We are the experts. We have been following the regulations for a long time. We have been preparing our staff and preparing materials that will make the transition from the old OSHA or WHMIS hazard communication system easier for everyone. We understand the challenge and the time that will be involved, and we will be there to make it as painless and easy as possible.
