Prepared for NC ASSE by Stephen Wrightenberry – Intern Cree EHS
Presented by Erin Hite – EHS Program Manager, Cisco Systems
ASSE Chapter meeting 12/13/12
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Overview of a sample plan to implement GHS in an
industrial setting.
◦ Objectives
◦ Challenges
◦ Plans and ideas
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Will include tips and things to think about as you
implement the program at your worksite.
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Will not be a detailed review of the changes to the
regulation (hopefully you already know the details!).
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See handout for side by side comparison of 1994
and 2012 Haz comm regulation changes
Sections with changes:
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Purpose
Scope/Application
Definitions
Hazard Classification
Written Program
Labels
Safety Data Sheets
Employee Training
Trade Secrets
Compliance Plan Step
Planned Completion
Date
(Compliance required)
Update and Publish the internal Hazard Communication
Program.
June 1, 2013
(June 1, 2016)
Train employees regarding the new label elements,
safety data sheets (SDS) format and provide any
additional employee training for newly identified physical
or health hazards.
June 2013
(December 1, 2013)
Update existing labels at the site
Start July 2013
(June 1, 2016)
Update existing MSDSs with newly formatted SDSs
provided by the chemical manufacturer/importer.
Ongoing
(June 1, 2016)
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Timing for implementation – SDSs are already becoming available
everywhere, need to train employees on how to read.
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Training needs to cover:
◦ Changes to HazCom, 16-section SDS, new label requirements, new classification
system, any newly identified physical or health hazards on new SDSs to include in
employee training
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Include new label information in training
◦ Since there will be new Manufacturer labels – if internal labels remain the same it
will be confusing for employees.
◦ New SDS will have classification numbers that are opposite of NFPA labels that
are currently in use (1 is highest hazard rather than lowest hazard)
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Classification system is more complicated. Individual employees may not
be able to make label choices without EHS assistance.
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Pictograms – new for employees – different from numbered hazard rating
• Online Powerpoint class – required
for all employees.
• Updated website – with links to
information and contacts for help
• Posters – for work areas, gowning
rooms, break rooms, bulletin boards
• Badge Cards – for employees to carry
• Newsletter – company wide prior to
training.
Sample Badge Card
Sample Poster
Materials from: GHS Compliance Kit KHA Online-MSDS
1)
2)
3)
4)
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12)
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15)
16)
Focus in
Identification of the substance or mixture and of the supplier
employee
Hazards identification
Training will be
Information on ingredients (composition) substance/mixture
on changes to
First Aid Measures
these sections
Firefighting Measures
Accidental Release Measures
Handling and Storage
Exposure controls/Personal protection
Physical and Chemical Properties
Stability and Reactivity
Toxicological
Ecological Information (Non-mandatory)
Disposal Considerations (Non-mandatory)
Transport Information (Non-mandatory)
Regulatory Information (Non-mandatory)
Other information including information on preparation and revision of the SDS
Chemical
Identification
Classification
and how to
Pictograms Interpret
and what
they mean
Hazard
Statements
Handling
Response
and
Prevention
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LOTs and LOTs of labels!
◦ Includes: squeeze bottles, equipment, tanks, hoods, buckets,
beakers, jars and on and on!
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Larger labels required – with inclusion of pictograms, hazard
statements and other requirements. What to do with small
containers?
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Difficult to use preprinted labels for the multitude of chemicals (need
all sizes, pictograms can’t be blank, who manages)
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Manufacturer label pictograms need to be in color – determine if
internal labels will follow this rule – requires specialized printers.
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Finding printers made in the US to print updated labels (Printers
available in the UK as of now; US is slowly transitioning printer
labels over).
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New HazCom regulation allows employers to use
existing workplace-specific labeling systems as
long as they provide the required information.
However, existing systems may not match what
will now be on manufacturer labels and on the
SDS.
◦ Leads to confusion for employees so implementing
consistent format is a good idea.
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Company is using NFPA/HMIS
Labels on all non-manufacturer
containers and equipment.
NFPA
HMIS
NFPA labels use number system to
Rate the hazards.
◦ 4 is high hazard, 1 is low hazard
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GHS labels will have pictograms
and hazard statement, SDS will
classify using numbers
◦ 1 is high hazard
Sample GHS
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Internal labels should have the following:
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Product Identifier
Pictogram
Signal Word
Hazard Statement(s)
Other:
◦ Precautionary Statement(s)
◦ Manufacturer contact info
BIG!!
Will need glasses to
read if use all this
information if used
on secondary
containers!
• As you can see, the format may differ as long as
the required information is present.
• May need to have several options available for
internal labels to accommodate container size and
type of hazard.
• Manu. labels require
red outlines for
pictograms.
• Blank diamonds are not
permitted on a label
from manufacturer, but
currently ok for site
labels
• Might change!
• Black out
pictograms that are
not applicable?
• Need to train
employees how to
complete label
• What to do if updated
SDS is not available?
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Using in house printing will cut time in receiving labels and will also
expedite the process, since labels can be designed, printed, and
then posted.
Important to find a cost effective printer that can handle all
necessary applications.
Would be great if integrated with existing MSDS system so labels
would auto print based on specific MSDS information.
◦ MSDS online system
 Costs for uploading new SDSs,
 Implementing label printing module (configure information
from MSDS to label, train employees on how to use)
◦ Manpower for requesting updated SDSs from all
manufacturers
◦ What to do when you don’t have an updated SDS?
(product no longer made, manufacturer out of business,
outside of US etc)
◦ Who reviews for any newly identified physical or health
hazards?
From: sigma-aldrich.com/safetycenter.html
This is a good reference
for EHS professionals to
check classifications and
make label choices if
MSDS is not available.
http://www.labcluster.com/news4/3033
4_ghs_poster_eu.pdf