Hazards in Focus
IHs Prepare for Wave of New SDSs, 
Labels under GHS ​

More than two and a half years have passed since OSHA released its revised Hazard Communication Standard (HazCom 2012), aligning it with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Employees received training on the new label elements and safety data sheet format by December of last year, and as of June 1, 2015, all safety data sheets (SDSs) and labels must comply with the new HazCom 2012 requirements.

With less than a year to go until the compliance deadline, industrial hygienists and occupational health and safety professionals in the U.S. are beginning to feel the effects of GHS on the workplace. Many changes are still to come before the revised standard is fully implemented. By June 2016, employers will be expected to have updated their hazard communication programs as necessary and trained employees on any newly identified hazards. FLOODED WITH INFORMATION With next summer’s deadline for HazCom 2012 compliance looming, industrial hygienists are still not seeing many of the new SDSs and labels popping up in their workplaces, according to Denese Deeds, CIH, co-founder and senior consultant at Industrial Health & Safety Consultants, Inc. in Shelton, Conn. Deeds explains that the process of converting SDSs and labels to meet the HazCom 2012 requirements has been slow, with some companies still struggling to properly format SDSs and get their SDS authoring software working correctly. Other companies are stuck waiting for chemical suppliers to provide information about the hazards and classifications of the substances they use in their formulations before they can complete their own SDSs and labels. And in some cases, Deeds says, chemical manufacturing companies are waiting to release their updated hazard communication materials due to concerns that the new labels will make their products appear more hazardous than their competitors’, a fear grounded in society’s desire to use safer chemicals. Printing considerations for labels, such as developing the new label format and purchasing printers that can print red borders, are also contributing to the delays.
“I am seeing some labels and SDSs coming in with the pictograms and hazard statements,” says Anne Bracker, MPH, CIH, an occupational hygienist who does private sector consultation for Connecticut OSHA. “But it isn’t overwhelming yet. Those doing the classification and categorization are doing the heavy lifting right now.”
Deeds predicts that most of the new SDSs and labels will appear in workplaces in midwinter or early spring. “Industrial hygienists in manufacturing facilities are going to be flooded with information,” Deeds says. “It’s going to be very difficult for them to keep up with reviewing the safety data sheets for changes and new classifications and communicating that information to workers.” QUALITY AND T​RUST As companies learn to navigate the new requirements under the revised standard, Deeds stresses that industrial hygienists and OHS professionals need to familiarize themselves with GHS and the basics of classification so they can determine whether an SDS is compliant and if the information it contains is adequate. Particularly during the first wave of new SDSs, it will be important for IHs and OHS professionals to reject poor quality safety data sheets and insist that those suppliers provide them with correct information, Deeds says. 
“I encourage industrial hygienists to become critics of safety data sheets,” she continues. “You need to be able to trust the information you get from your supplier so that you can make an independent judgment as to whether the classifications are correct.”
Given the speed with which complex new chemicals are entering the market, suppliers may be among the only sources of information for chemical composition, making it even more important for IHs to be able to trust SDSs. However, there will always be instances in which industrial hygienists don’t completely trust the classification from a supplier. In these cases, IHs can turn to robust online sources for studies and information on which to base their conclusions about chemical hazards.
Deeds credits the worldwide changes related to GHS with the recent surge in resources on chemical information. For example, a website developed by the Organization for Economic Cooperation and Development, eChemPortal (www.echemportal.org), allows users to search more than 30 databases by chemical name, number, and property for information on chemical substances. The European Chemicals Agency website (http://bit.ly/echachemicals) also houses a large amount of information on chemicals collected under the EU’s Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation on the safe use of chemicals.
“I hope industrial hygienists are taking advantage of the fact that they can do their own investigation about the hazards of a chemical that they’re either using or thinking about using,” Deeds says. “We have the opportunity to verify [chemical information] independently in a way that we never could before.” NEW CHALLENGES “GHS is changing the way industrial hygienists work in that there is a lot more work to do,” says Tom Grumbles, CIH, senior specialist, product safety for Sasol North America.
While industrial hygienists work to make sense of the new information under GHS, one of the biggest challenges will be transitioning from the old material safety data sheets (MSDSs) to the new SDSs. For example, the 16-section format of the new SDS likely won’t match an old MSDS, making it difficult for IHs to compare new SDSs with previous MSDSs. Disclosure differences and changes to mixture rules under the revised standard will also prove problematic for industrial hygienists trying to assess whether a formula has changed or if a substance has different hazards.
Once mixtures are classified according to GHS, there may very well be even more materials that are classified, labeled, and have an SDS, notes Grumbles. Some new classifications will make it necessary to provide hazard communication training for substances that haven’t been covered before. Grumbles says this new requirement has the potential to create communication challenges with employees or customers who will want to know why they weren’t informed of these hazards before, when in fact the substances weren’t considered hazardous under the old standard.
Deeds, a registered SDS and label author, explains that the changes in the cutoff concentrations for mixtures are much more stringent under the revised standard. For everything except carcinogens, it used to be that a hazardous ingredient had to make up one percent of a mixture for the mixture itself to be classified as hazardous. But now a cutoff concentration of one-tenth of a percent applies to sensitizers, reproductive toxins, and germ-cell mutagens. In writing new SDSs, Deeds says she is already seeing the impact of these new cutoffs, particularly for products that contain fragrance ingredients and preservatives, which are skin sensitizers. Products using more than 0.1 percent of these types of ingredients will become classified as hazardous for the first time under the new cutoff concentration.
When the new mixture rules kick in for a particular product, the classification may suddenly carry a hazard that nobody was aware of,” Deeds says. “That’s the kind of thing that IHs are going to have to watch for and decide whether it changes anything or not.”
On a bigger scale, Grumbles notes that industrial hygienists and OHS professionals will have to find ways to manage differences and nuances in hazard communication worldwide even though HazCom 2012 has brought GHS to the U.S. 
“Close to home, Canada recently announced their approach to GHS that’s pretty much aligned with the U.S., so that helps due to proximity,” Grumbles says. “But if you’re going to Europe or Taiwan or some of the other major trading blocks, there are differences in SDS and label requirements that’ll have to be managed somehow.” LEARNING BY EXAMPLE Industrial hygienists working for multinational companies with facilities outside the U.S. have an advantage over their domestic counterparts in some cases. Global companies may have already gone through the process of implementing GHS if other countries in which they operate required compliance sooner. For example, Grumbles watched his counterparts in Italy, Germany, and Slovakia take on the new requirements of GHS and was able to learn from their implementation experiences and frustrations. 
“It sounds silly, but early on it got down to things like two-color printers,” Grumbles says. “Most hazard communication systems would print labels in black and white, but GHS requires more than one color: red borders and other things. That’s the kind of thing that can be technically challenging and also not cheap.”
Although lessons like these are not necessarily analogous since regulations vary from country to country, Grumbles states, they are still valuable. Global companies have a unique set of challenges related to variations in regulations and requirements between countries. Grumbles explains that these inconsistencies are based on the way that different countries have implemented GHS and choices they could make within the GHS system. The management of hazard communication documents and labeling becomes especially difficult for companies operating and moving products around the world. 
“If you have good software systems that are fairly nimble, you can generate country or regional templates that allow you to account for differences between countries,” Grumbles says. “If you don’t, you’re going to have to make hard decisions on whether you write your SDSs to the most stringent requirements where you do business. If you do that, in general you’re probably going to comply with the countries that have less strict requirements.” A POSITIVE OUTLOOK Though The Synergist’s sources agree that it’s too early to tell for sure, employees in the U.S. seem to be reacting well to the changes occurring around GHS. Bracker, who was involved in the awareness training that was required before December 2013, says it’s her experience that employees are positive about the new SDS format and pictograms and that they like the fact that labels are more comprehensive. 
“When we provide employees with training on the pictograms, we have the chance to discuss a product’s potential hazards and some basic toxicology concepts,” Bracker explains. 
Reviewing the health hazard pictogram gives trainers the chance to address the concept of chronic health effects and the importance of referring to hazard statements to learn more about the nature of hazards, Bracker says. Similarly, discussion of the skull-and-crossbones and exclamation mark pictograms introduces the concepts of acute toxicity, hazard severity, and the value of signal words.
Deeds adds that employees are enthusiastic about the more conspicuous portrayal of substances’ classifications. 
The revised standard is an opportunity for employers to review and refresh their hazard communication programs, according to Bracker. The consistent labeling requirements will help employers identify the most hazardous materials in the workplace, pinpoint chemicals they may want to substitute, and learn of new health effects that they may not have been informed of under the old system, she notes.
In the meantime, the implementation of GHS in the U.S. remains a work in progress as IHs and OHS professionals watch for the wave of new SDSs and labels coming in 2015. 
“After we get transitioned, safety data sheets—if they’re done correctly—are going to be much more valuable tools to industrial hygienists,” Deeds says. “Because the standardized hazard statements and classifications are so precisely disclosed, it’ll be a lot easier for industrial hygienists to identify the more hazardous chemicals, decide where they may need to take action, and compare the hazards of one product versus another.” KAY BECHTOLD is assistant editor for The Synergist. She can be reached at kbechtold@aiha.org or (703) 846-0737.
SDS AND LABEL AUTHORS: GET CREDENTIALED The SDS and Label Authoring Registry recognizes chemical hazard communication and environmental health professionals who specialize in writing safety data sheets and labels. The “Registered Specialist: SDS and Label Author” credential is the first one to provide recognition for individuals who have the skills and knowledge to properly prepare or review SDSs and labels to meet GHS requirements. 
The SDS and Label Authoring Registry was co-developed by the AIHA Registry Programs, LLC®; AIHA; and the Society for Chemical Hazard Communication (SCHC) to ensure the recognition of competent professionals. 
For more information, visit http://bit.ly/sdsregistry.