After a multiyear phase-in, the final implementation step for the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) took place in June 2016. However, both manufacturers and clinical laboratories still are working their way toward full compliance with this system of worldwide uniform chemical classification and labeling. The United States adopted GHS in 2012 as an update to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication standard, and GHS applies to any employer that uses hazardous chemicals in the workplace.
Employers faced an employee training requirement in 2012, followed by two deadlines in 2015—one mandating that chemical manufacturers change their labeling, and the other necessitating standardized Safety Data Sheets (SDS). The last implementation step involved ensuring compliance in the lab with all new labeling requirements, signage, and chemical-handling policies. Given these requirements, clinical laboratories should review four areas to determine whether they have achieved compliance with GHS.
The first thing labs should check is their chemical labeling. The GHS introduced specific and universal labeling elements for primary (manufacturer) chemical containers. Every label must contain the chemical identity, a signal word (danger for more toxic chemicals, warning for lesser hazards), universal hazard symbols or pictograms, manufacturer information (such as company name, address, and telephone number), precautionary statements and first aid information, and hazard statements that describe the nature and degree of the hazard. Chemical manufacturers were given time to convert to the new labeling convention, and both manufacturers and labs were given time to use up their old stocks of non-GHS labeled chemicals.
At this point, laboratorians should check their chemical labels to see whether the lab still has older chemicals that do not have GHS-compliant labels. OSHA does not allow re-labeling a primary container, so if your lab has a larger volume of a chemical you don’t wish to dispose of, you could pour it into a properly labeled secondary container.
OSHA also requires that secondary or pour-off chemical containers be properly labeled. GHS labeling is acceptable, but labs may also use other standard labeling conventions such as National Fire Protection Association (NFPA) or Hazardous Materials Identification System warning labels, along with the chemical identity. The GHS hazard ratings (1–5) are opposite those of the NFPA convention, and this has caused confusion. However, because there is no requirement to use GHS ratings on labels, OSHA has allowed the continued use of NFPA ratings on secondary containers.
Safety Data Sheets
Another offshoot of GHS implementation is that SDS—formerly known as material safety data sheets—have been standardized. All chemical manufacturers should now be providing the standard 16-section format with their products. The updated SDS should have pictograms and ordered hazard information. Whether your lab keeps paper copies or uses an electronic system, check the SDS for chemicals in the lab inventory to ensure a GHS version is available.
In addition to labeling updates, GHS also requires a change in lab signage having to do with OSHA’s formaldehyde standard, which was altered slightly as part of GHS. If formaldehyde exposures in the lab are determined to be above the limits set by OSHA, a warning sign should be posted in the area.
Previously, the sign’s specific wording was:
IRRITANT AND POTENTIAL CANCER HAZARD
AUTHORIZED PERSONNEL ONLY
The updated GHS version must now read:
MAY CAUSE CANCER
CAUSES SKIN, EYE, AND RESPIRATORY IRRITATION
AUTHORIZED PERSONNEL ONLY
The Laboratory Chemical Hygiene Plan
The final check for GHS compliance involves a lab’s overall chemical management plan. OSHA’s chemical hygiene standard requires a lab chemical hygiene plan that includes specific elements. In addition to specifying the laboratory director’s responsibilities, the chemical hygiene plan also must designate a chemical hygiene officer, have policies for all operations that involve chemicals, establish criteria for the use of personal protective equipment, specify a process for exposure monitoring, and outline provisions for medical examinations and employee training.
This comprehensive laboratory chemical hygiene plan should have been updated to comply with the GHS. Double-check that all the wording is correct, and include updated labeling instructions as described above. Change “MSDS” to “SDS” in the document, and update any older references.
The road has been long from the 2013 GHS training requirement to the final hazard communication implementation in 2016, and not everyone is ready. Some chemical manufacturers could not meet OSHA’s 2015 deadlines, and they still are distributing products with outdated labels and SDS. If OSHA inspectors investigate and see that the company is actively working toward compliance, they will be lenient. The same is true for labs. If your lab is not fully compliant with GHS, keep working toward this required goal as you look ahead to the next round of new regulations.
Daniel Scungio, MT (ASCP), SLS, CQA (ASQ), is laboratory safety officer for Sentara Healthcare Laboratory Services in southeast Virginia. As Dan the Lab Safety Man, he also serves as a laboratory safety trainer, speaker, and consultant. +Email: [email protected]