I thought we had this discussion a few months ago as the December deadline neared….

 

OK my 2 cents…..feel free to fire at will….oh and I agree with Ron on the loose comparative between systems.

 

Anyway, it was my understanding that for workplace labeling, and for that matter, secondary container labeling in the workplace, as long as the labeling does not conflict with or cause confusion between systems it is acceptable.  OSHA did not change the general requirements for workplace labeling.  Employers have the option to create their own workplace labels, signage etc.  If the requirements for HazCom 1994 are met then all is well (or at least compliant) in the HazCom world in regards to communicating the hazard to a worker.  Now having said that, YES there will be confusion.  YES there already is confusion….and that includes confusion as to where does GHS really apply to us in the USA, i.e. where is it mandatory.  Everybody HAS to be trained to recognize these labeling and hazard communication elements, but where/how do we apply it to our work place.

 

For our small, private college inventory of roughly 3,000 chemicals we have kept our NFPA door/building signage, we have kept our HMIS secondary container labeling AND have added HMIS  labeling to (not in place of) incoming containers for the “at a glance” advantage of the “familiar old system”.  However, we completed our initial trainings by the deadline and continue to train on GHS familiarization.  Yes, the exclamation point is probably one of the more confusing elements because of it’s general “vagueness”.   

 

I imagine that our situation doesn’t apply to everyone.   We work with a wide variety of chemicals….but in small quantities.  We don’t “manufacture” chemicals to ship out so we don’t have to provide GHS labeling or GHS-SDS to ship out to a consumer with the chemical.  However, we do receive chemicals with GHS labeling, and the GHS-SDS and we keep/maintain up-to-date SDS.  Unless, or until, NFPA changes their coding/labeling/placarding system we won’t change our door signage because we don’t want a firefighter to come in and wonder what the crazy pictures are all about when they are so familiar with the diamond….not to mention I don’t believe the GHS system relates to how a chemical acts/reacts etc under FIRE conditions like NFPA system is supposed to.   Diamonds for fire-fighters, HMIS for secondary containers and supplemental labeling for our workers.  GHS for received chemicals and incoming labeled products and HazCom-SDS. 

 

Another personal opinion inserted…..even if the SDS doesn’t have the HMIS or NFPA codes….if you gather up enough SDS for a chemical you can get a rough idea (if you know the HMIS classification system well enough)  to make a decent at-a-glance HMIS label….even though the 4-5 SDS that you gathered really DON’T agree on how hazardous the chemical really is!

 

Anyhoot, I could go on and on about this as I am sure any of us who have been mired in HazCom training AND practical application of the systems can…we all have opinions and they won’t always agree.

 

Here is a quote from “OSHA BRIEF: Hazard Communication Standard:  Labels and Pictograms” under the workplace labels section: (and here is the URL: https://www.osha.gov/Publications/OSHA3636.pdf )

 

 

“ If an employer has an in-plant or workplace

system of labeling that meets the requirements

of HazCom 1994, the employer may continue

to use this system in the workplace as long

as this system, in conjunction with other

information immediately available to the

employees, provides the employees with

the information on all of the health and

physical hazards of the hazardous chemical.

This workplace labeling system may include

signs, placards, process sheets, batch tickets,

operating procedures, or other such written

materials to identify hazardous chemicals. Any

of these labeling methods or a combination

thereof may be used instead of a label from the

manufacturer, importer or distributer as long

as the employees have immediate access to

all of the information about the hazards of the

chemical. Workplace labels must be in English..

Other languages may be added to the label if

applicable.”