The New Meaning of Flammable: How Will GHS Changes Affect Your Organization?
Over three years have passed since the Occupational Safety and Health Administration (OSHA) officially adopted the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). To help the transition, it set a series of compliance deadlines, all of which have since passed except for one. That final deadline comes up on June 1, 2016, when everyone covered by OSHA’s Hazard Communication Standard must be in full compliance with the new regulations.1
June may seem like it’s a long way off, but six months isn’t much time, especially when many companies appear to be struggling with instituting the new changes. A recent survey revealed that only 45% of affected companies were able to meet the previous June 1, 2015, compliance deadline. Of the firms that failed to comply, 65% said they needed another 6-12 months to do so successfully.2 These numbers don’t bode well for 100% compliance from all affected organizations by June.
Difficulties that Have Arisen from GHS Changes
For the most part, companies have focused on updating chemical labels and safety data sheets—and for good reason. Everyone who handles chemicals in some way, from manufacturers to downstream users, is affected by the changes. Suppliers must ensure the chemicals they ship out use the new labels. They also have to send updated safety data sheets to users who request them. Conversely, laboratories must remain vigilant that new chemicals being received on-site have the new labels and that their safety data sheets contain the updated information. Otherwise, they’ll be non-compliant and subject to an OSHA violation should there be an inspection of their facility.
Unfortunately, the onerous task of updating labels and safety data sheets isn’t the only difficulty facing organizations. The new GHS regulations have altered the standards used to categorize chemicals. In fact, one such category—combustible liquids—no longer exists. Instead, it has been merged with the old category of flammable liquids to form a new, larger flammable liquid category.3 Despite the cumbersome changes the new standards bring, storage requirements for the new flammable liquid category aren’t actually different from the old ones.
Sounds great, right? Not so fast. The new flammable liquid category is further divided into subcategories, dependent on flash points and boiling points. As a result, some chemicals have been recategorized. For example, Category 3 flammable liquids now include chemicals that were once labelled combustible as well as materials that were previously classified as flammable under the old system. In a nutshell: it now covers a wider range of flash points than the old classification. The problem is that the break point for many storage requirements falls right into the middle of this range—meaning that the way you store one Category 3 flammable liquid might be different from how you store another Category 3 flammable liquid.
Chemical Management Helps Companies Cope with the New GHS Regulations
Reclassified hazardous chemicals. New container labels. Updated safety data sheets. The amount of work required to comply with the new standards makes my head spin. Thankfully, there are tools available to ease the transition. Digital chemical management enables users to keep on top of necessary changes and meet updated regulations. Some common features include:
- The ability to track the lifecycle of a chemical from receipt to disposal. By tracking these dates, users can determine whether these chemicals should follow the new labelling guidelines.
- The ability to access linked safety data sheets from within the system, eliminating the need for dusty, rarely used paper binders. Just as with the new container labels, users will be able to see if they need to request new safety data sheets from the manufacturer.
- The ability to look up newly reclassified chemicals and establish whether a change in categorization necessitates new safety measures or training for employees.
Growing pains are inevitable any time there is a change in established standards. OSHA’s adoption of GHS has only driven that point home. Meeting compliance deadlines may seem impossible, especially if your facility houses thousands of chemicals in its inventory. Nevertheless, it must be addressed or else you risk facing the consequences—in this case, an OSHA violation.
Does your organization need help meeting the new standards put forth by GHS? Are you overwhelmed by the amount of work required to update your existing hazardous chemical safety information? BIOVIA CISPro is a chemical management system that empowers your company’s chemical safety program. Its tools support effective inventory tracking, safety data sheet management and regulatory compliance. The solution also allows for customization based on your company’s size and geographic location. If you’d like to streamline your chemical management processes, please contact us today to learn more about BIOVIA CISPro and request a demo.
- “The Day After OSHA’s Big GHS Deadline: What’s Changed?” June 2, 2015, https://www.msdsonline.com/blog/compliance-education/2015/06/02/the-day-after-osha-s-big-ghs-deadline-what-s-changed ↩
- “Chemical Firms Are Unprepared for GHS Regulations,” December 11, 2015, http://mhlnews.com/facilities-management/chemical-firms-are-unprepared-ghs-regulations ↩
- “But It Wasn’t Flammable Before! GHS Changed the Meaning of Flammable Liquids,” September 23, 2015, http://ehsdailyadvisor.blr.com/2015/09/wasnt-flammable-ghs-changed-meaning-flammable-liquids/ ↩