Transition to GHS label compliance
By Del Williams
November 28, 2016
By Del Williams
Paint and coating formulators, distributors and end users must now ask if their chemical labels are GHS compliant – and if not, be prepared to document for OSHA their good faith efforts to become so, including an expected timeline for reaching compliance.
The industry will also need to determine how to integrate such compliance with the American Coatings Association (ACA)’s Hazardous Materials Identification System (HMIS). (See the sidebar below for regulation dates and compliance in Canada.)
The “Globally Harmonized System” (GHS) was established by the United Nations to create a unified system for identifying and communicating hazardous chemicals. In the U.S., OSHA set a June 2015 deadline for chemical manufacturers to use GHS compliant labels, followed by a December 2015 deadline for distributors, and June 2016 deadline for end users.
As such, paint and coating formulators must re-classify any products containing hazardous chemicals based on a common chemical classification system defined by GHS. They must update their safety data sheets and use GHS-compliant labels to identify their hazardous chemicals.
Paint and coating importers and distributors, in turn, must ensure that any products with hazardous chemicals they sell have GHS-compliant safety data sheets and GHS-compliant labels.
For those currently using HMIS labels for in-plant containers, related written documentation, and training, the question is how to achieve GHS compliance and integrate it with HMIS, which has been a paint and coatings industry standard for decades. Though differences exist in the two systems, such as opposite numbering for the level of hazard, OSHA allows employers to use HMIS in the workplace as long as it is consistent with GHS (HCS 2012) and workers are properly trained for GHS.
Instead of investing in costly dedicated printer/label/software systems, small to medium sized companies are easing the transition to GHS label compliance. More are turning to flexible, lower cost options, such as industrial-grade labels from Avery, that allow printing durable GHS, HMIS, or hybrid labels on demand with existing laser printers and certain inkjet printers.
Avery designed its UltraDuty GHS Chemical Labels to meet the most rigorous GHS requirements. The durable synthetic labels are chemical resistant, tear resistant, abrasion resistant and constructed with a marine-grade adhesive that is waterproof and passes a 90-day seawater submersion adhesion test. Unlike typical labels, which crack and harden in harsh conditions, they are UV resistant with 2+ years of outdoor UV life.
“Staying GHS compliant will not only help paint and coating industry organizations avoid OSHA fines, sanctions, or auditing, but also will help them open new global markets since GHS is a global standard,” says Glen Markham, vice president of Business Development at RightAnswer.com, Inc., a chemical compliance and information specialist.
Avery provides such GHS and HMIS-compliant label software at no cost. The Avery Design & Print GHS Wizard makes it easy for employees to create and print their own GHS and HMIS labels from pre-designed templates.
No download is required since the software operates from Avery’s website (www.avery.com/GHS), and GHS and HMIS labels can be securely saved online or to a computer.
To help companies stay compliant for GHS, HMIS, and other regulatory situations, including OSHA safety communication, Avery has partnered with RightAnswer through a portal in Avery’s website.
For more info, visit www.avery.com/GHS.
Del Williams is a technical writer based in Torrance, California.
Target date for implementation of GHS in Canada
The Hazardous Products Regulations were published in Canada Gazette, Part II on February 11, 2015. Both the amended Hazardous Products Act and new regulations are currently in force. “In force” means that suppliers may begin to use and follow the new requirements for labels and SDSs for hazardous products sold, distributed, or imported into Canada.
A multi-year transition plan has been announced. From now until May 31, 2017 suppliers (manufacturers and importers) can use WHMIS 1988 or WHMIS 2015 to classify and communicate the hazards of their products (suppliers must use one system or the other). Beginning June 1, 2017 to May 31, 2018, distributors and suppliers importing for their own use can continue to use WHMIS 1988 or WHMIS 2015.
Access the Canadian Centre for Occupational Health and Safety fact sheet spelling out the regulations and compliance dates for industry.