Frequently Asked Questions

1. Do I need to maintain an MSDS/SDS for every chemical in our workplace?
2. What is the requirement for training my employees when they are using hazardous chemicals?
3. What is the difference between the HMIS/NFPA and the GHS numerical hazard ratings?
4. Where is Control Banding being used and is it anticipated to be introduced into the US Workplace.
5. Does GHS address the frequency of training? Must it be provided one time or annual for example?
6. After the GHS standard is rolled out, to what degree with the US standard be in line with the rest of the international community? Will there still be difference we have to still deal with?

Answer 1:

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Answer 1:

According to the rule an MSDS or SDS must be maintained for every chemical in any form (solid, liquid, gas, vapor, and even mist, dust and powders) that contains a physical or health hazard that could adversely affect an employee.

 

Answer 2:

According to the new US OSHA GHS rule change you must train your employees on each chemical hazard they may be exposed to in their work area before they work with the product and each time a new hazard is introduced. Training employees on just the MSDS/SDS contents is acceptable as long as you can demonstrate that the employee clearly understands the hazards and protective measures.

 

Answer 3:

The GHS numerical hazard level rating system is exactly the opposite of NFPA and HMIS. For example, if the health hazard in blue diamond is signified with the #4 then the chemical is assumed to be an extreme health hazard and conversely if the chemical is rated as a category #4 following the GHS guidelines then it is a low level hazard. The pictogram will give you a clue however if you pay attention.  For instance, the pictogram for a category #4 low level hazard would be the exclamation mark whereas the pictogram for a category #1 acute toxin is the skull and crossbones.

 

Answer 4:

Control banding or risk assessment is currently being utilized in the UK and parts of Europe. Following the guidelines established by this method of assessing risk employees would be less likely to be exposed to hazardous conditions because measures are taken as a component of the assessment.

Some US companies are already utilizing this methodology to reduce risk in their workplace but it will likely be at least three years before it is mandated by OSHA.

 

Answer 5:

GHS does not specifically call out training, but when OSHA adopted GHS as a component of the hazcom standard the rule was amended to clearly state that training must insure that employees “understand” or comprehend the hazards they are exposed to. It is no longer enough to just point an employee to an MSDS/SDS and assume they can interpret the technical information.

 

Answer 6:

Many countries are far more advanced than the US regarding GHS but once fully implemented every nation that adopts GHS will be utilizing standardized SDS, pictograms, signal words, hazard and precautionary statements etc.

There will be differences yes but these differences will only affect your company if you are doing business in foreign countries. For example, in the US we use four (4) levels of toxicity where other nations only recognize three (3).