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new safety data sheets with older ones to
see if any new hazards have been identified
that employees will need to be trained on.
A good electronic system can simplify the
comparison of multiple documents.
GHS and HazCom Compliance
Going Forward
The best way to get started on compliance
with HazCom 2012 is to ensure compliance
with HazCom 1994. For employers this
means having a HazCom plan, an up-to-date
chemical inventory, the proper use of labels,
maintaining safety data sheets, and training
employees on chemical hazards. Following
is a list of 15 steps that every company cov-
ered by OSHA’s adoption of GHS should be
working toward:
• Designate a GHS transition leader.
• Get educated on GHS.
• Inventory chemicals (physical inventory).
• Check inventory against safety data
sheet library.
• Acquire missing safety data sheets.
• Safely dispose of chemicals no longer
in use/needed.
• Archive safety data sheets no longer
in use.
• Train employees on GHS label
elements and SDS format.
• Prepare for safety data sheet churn.
• Look for new hazards on incoming
safety data sheets.
• Get secondary container labeling strategy.
• Train employees on any new hazards.
• Update written HazCom program.
• Meet SARA/EPCRA reporting
obligations.
• Stay current on GHS.
Going forward, chemical management
should be about keeping abreast of changes
to existing laws and regulatory lists, while
keeping another eye on marketplace solutions. By using a common sense approach
and taking advantage of advancements in
technology, chemical management can be
one of the easier items on a safety professional’s to do list. Another helpful attitude
to embrace is the idea that chemical management is not a fixed goal. There is no
magic finish line. As the regulatory environment continues to evolve, so will the compliance obligations of chemical manufacturers, distributors, and employers.
Too often, companies want to know
what is the least they have to do in order
to comply with various regulations; that
is fundamentally the wrong approach. A
better approach is to get out in front of reg-
ulations. If the question is not “What’s the
minimum I have to do to comply?” and is
instead, “How can I best keep employees
safe, the environment healthy, and be a good
steward of resources?” then chemical man-
agement compliance gets easier.
Today, doing right by employees in terms
of chemical hazards is also good business.
Companies cannot afford the lawsuits, negative image, and downtime that comes with
non-compliance. Conversely, many companies are finding the marketplace rewards
“good behavior.” Ultimately, chemical management boils down to keeping employees
and the community safe, so everyone can go
home at the end of the day.
Glenn D. Trout is the president of
MSDSonline, provider of on-demand compliance solutions for tracking and managing
hazardous chemicals and safety data sheets,
GHS compliance, and other critical EH&S
information. Visit www.MSDSonline.com for
more information.
