I recently attended a Environmental themed conference. Nearly 5000 professionals in Environmental, Health and Safety were there. I saw many things at the show, but nothing surprised me more than seeing standing room only — and a line out the door — for one event.
What was it? It was a talk on GHS, the Globally Harmonised System of Classification and labeling of chemicals. I mean — it was a general talk. Just a lay-of-the-land kind of talk.
Now, call me crazy, but I had to pull a high-level EHS association official aside and ask, “Really — are people really that confused about GHS? You add a couple of sections onto the MSDS and use slightly different pictograms. Why all the commotion?”
The official nodded slightly as if she understood the question. She said it was true that most companies may have a GHS solution built in with their current MSDS management system. But then she explained why there were lines out the door for general GHS information. So for those who — like me — are puzzled by the fuss over GHS, this one’s for you.
Understanding the new GHS. To help understand the fuss about the US Occupational Safety and Health Administration’s (OSHA) newly final Hazard Communication Standard (HCS), it’s important to realize that this rule is OSHA’s most comprehensive rulemaking in a decade. Of this I was reminded.
The updated HCS impact affects over five million businesses. These are manufacturers, and to some extent distributors, that use or store chemicals. Plus, the new HCS affects almost 100,000 chemical manufacturers, importers, and distributors.
Because the new rule is a major revision of the HCS, OSHA is requiring employers to train all employees on the new rules. Training is expected to impose the bulk of the cost burdens on US businesses.
Software for GHS won’t be much different from the current MSDS vault type programs companies use today. So training there should not be required, except for label making differences. Outsourced and SaaS solutions pose few training challenges — because these can be adjusted anytime, in real time. (SaaS is like the cloud — but believed to be more secure.)
But if you don’t outsource MSDS and GHS already — now is a good time to start. Rather than accrue costs while piece-mealing SDS responsibilities under REACH, OSHA and now, effectively, GHS — some companies have found value in investing in a centralized, comprehensive, outsourced solution.
Billions of dollars at stake. While the big-picture changes aren’t so scary, the details of it will get cumbersome. Largely the folks lining up at conferences to learn more are the consultants. They have to know everything, in theory. There’s a lot of money at stake.
The new GHS introduces a set of criteria for classifying human health and physical hazards while identifying OSHA-defined hazards. It requires that companies classify substances and/or products to ensure the appropriate classifications are assigned. Chemical data and labels will often need revision — perhaps significantly — to conform to new document requirements as they emerge.
Achieving and maintaining compliance will be a complex and time-consuming undertaking for many companies. I’ve heard OSHA officials use the word “billions” when discussing total costs. (As soon as I can lock down a quotable source, you’ll hear about it here.)
Who’s attending “about GHS” forums? Attending is anyone who has an eye on the money, basically. No, that’s not fair. Also attending are folks really trying to learn as much as they can. Groups and their motivations include:
- Industry professionals seeking to understand / react to implications of the new HCS rule, so they can competently and strategically manage resources, budget, training, and compliance
- Leading regulatory compliance experts and industry representatives who provide strategic advice to a broad spectrum of industry clients relative to regulatory standards, rule-making, and compliance.
- Journalists trying to distill key insights and analysis of the OSHA HCS adopting GHS
- Folks seeking discussions the multiple impacts, risk factors and estimated costs to be incurred by employers and manufacturers
- Individuals looking to refine and discuss definitions for “substance,” “mixture,” and hazard “classification,” among other critically important new terms
- Executives analysing strategic planning considerations and potential compliance/risk exposures
Audience by professional role? Well, look out, here comes everybody:
- Environmental, Health, and Safety (EHS) Managers
- Product Marketing/Safety/Packaging & Labeling Professionals
- Human Resource Managers
- Fire Services Professionals
- International Marketing Professionals
- Compliance and Training Staff
- Environmental and Process Engineers
- Engineering and Plant Services Professionals
- Facility/Energy Planning Professionals
- Environmental Compliance and Reporting Management
- Monitoring/Environmental Resource Managers
- Environmental Health and Safety Management
- Production/Operations/Engineering/Environmental Management
- Environmental Consultants and Attorneys
- Environmental Risk Management Professionals
- Environmental/Corporate Counsel SVP/VP/Director
- SVP Finance/Engineering/Operations Management
- Power Plant Chief/Supervisor/Managers
- Physical Plant/Facility Management
If the question you ask yourself is, “Is this much ado about nothing?” then you’re probably all set. If you really do have questions about GHS solutions, sign up for a seminar or webinar soon, before it’s too late! I say that and am not even promoting such a thing. Just don’t get left out in the corridor like I did: people are hot on this trail right now and it’s standing room only.
Cheers, and, as always, happy compliance.
