Is Your In-plant Compliant with New OSHA Standard?

OSHA has updated the Hazard Communication Standard (HCS) by adopting the Global Harmonized System (GHS) of classification and labeling of chemicals. GHS replaces the provisions of the MSDS safety data sheet program, affecting virtually all businesses across the United States. The roll-out and implementation carries over several years, with an end date for conversion to occur no later than June 2016. First critical date was Dec. 1, 2013, for employee orientation training. Now that the date has come and gone, employers are to have completed the employee orientation, and are now expected to comply with the conversion requirements of the new standard or they can be cited and fined.

Your employees should now be versed in:

• Clear explanations of the new Hazard Communication Standard;
• What the Global Harmonized System is and who it impacts;
• Important changes to the MSDS format and training requirements; and
• Tips for keeping your HazCom program compliant with the new standard.

Each employee is responsible for the following:

• Know the location and use the information provided in the SDS;
• Ensure proper labeling of hazardous chemicals;
• Attend initial and follow-up hazard communication training as required;
• Report potential hazards, accidents and near-misses to supervisor immediately; and
• Assist management in implementing recommendations for improving safety and process procedures.

MSDS/GHS information is intended to provide employees and emergency personnel with chemical safety measures for handling or working with reactive chemicals, hazardous chemicals, hazardous substances and dangerous materials in a safe manner. In accordance with the United States Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard, anyone who might handle, work with chemicals or be exposed to hazardous materials must have access to a Globally Hazard Sheet's chemical safety information.

Once training is completed, the next step is to develop a compliance program for monitoring activity and accountability. There are 11 key steps in this process, defined as follows:

• A record of employees trained and documents in their files.
• A completed physical inventory of product and verification of SDS's.
• Employee reminder posters displayed through-out my facility.
• A log of when GHS data sheets were received, planned to be released and a process for distribution.
• A record retention plan in place for replaced MSDS sheets.
• Required updates to safety and business plans, HazCom program, and for hazardous materials transportation and site security.
• Evaluated the fire rating of my combustible storage area.
• A procedure for transfer of materials into secondary containers.
• A contractor awareness and checklist program to work at my facility.
• A structured system for identifying pipes and contents.
• Emergency procedures specific to their operation(s) and all affected employees must be aware of these procedures.

If you can't say "yes" to all the above, you've only scratched the surface on compliance.

The purpose of the GHS is to enhance the protection of humans and environment against hazardous chemicals, as well as to facilitate international standards. GHS requires chemicals to be classified based on their inherent properties or hazards and in accordance with certain classification criteria. The classified chemicals are assigned to a fixed set of GHS pictogram(s), signal word, hazard and precautionary statements.

Now that you are aware of the program, what's the impact to your business, and what should you do about it? Key questions center around: What are the changes, when do they need to be done, who will audit my performance, what are the penalties, who is impacted and why should I worry?

Did you know that for the past two years or more, fall protection (trips, falls and hazards) has been the most common violation for fines; but, in 2014, it is expected to be hazard communication?

Why? For years, businesses managed their hazard communication programs with spreadsheets or manual processes, typically delegating tasks to administrative staff. However, GHS requires more complex and detailed management of classification of chemicals, which far exceeds the capability of manual processes, legacy systems or spreadsheets to effectively manage hazard communications programs. This is one reason why industry leaders are increasingly implementing more robust information solutions that enable corporate managers and executives to address hazard communication throughout the organization as part of a comprehensive strategy for enterprise sustainability management. These powerful, integrated solutions reduce risks and costs by ensuring data quality and streamlining critical work processes across the organization. They also make it easier for companies to adapt to new standards such as GHS by providing a central point of leverage for change management.

So, with the aspect of looking over your hazard communication plan, your safety plan and other related policies and procedures, you will find that you are more than halfway to conducting a risk management evaluation on your entire operation. You can easily finish this exercise with a business impact analysis to assess the likely impact of current risks on your operations. The prevention, preparedness, response and recovery (PPRR) model can be used for developing a business continuity plan.

A business impact analysis identifies the activities in your operations that are key to its survival. These are referred to as critical business activities. You should consider things such as: the records and documents you need every day; the resources and equipment you need to operate; the access you need to your premises; the skills and knowledge your staff have that you need to run your business; external stakeholders you rely on or who rely on you; the legal obligations you are required to meet; the impact of ceasing to perform critical business activities; and how long your business can survive without performing these activities.

As part of your business impact analysis, you should assign recovery time objectives to each activity to help determine your basic recovery requirements. The recovery time objective is the time from when an incident happens to the time that the critical business activity must be fully operational in order to avoid damage to your business. Your business impact analysis will help you develop your recovery plan, which will help you get your business running again if an incident does happen. To conduct an analysis, ask yourself:

• What are the daily activities conducted in each area of my business?
• What are the long-term or ongoing activities performed by each area of my business?
• What are the potential losses if these business activities could not be provided?
• How long could each business activity be unavailable for (either completely or partially) before my business would suffer?
• Do these activities depend on any outside services or products?

How important are the activities to your business? For example, on a scale of 1 to 5 (1 being the most important and 5 being the least important), where would each activity fall in relation to the rest of the business?

When you update your risk management plan, you will also need to conduct a new business impact analysis. While GHS has prompted some additional tasks to be planned, why not use the resource and budget to further enhance the performance and risk exposure to your overall business? PI

About the Author

Dale Rothenberger has more than 20 years of experience in business transformation and program process management. He is available for consultation and can be reached at d.rothenberger@zeemedrdg.com or at (484) 239-6925.