Many questions have surfaced recently on the new requirements of container labeling under GHS, and the associated impact to companies.
In short, employers are required to provide secondary container labeling for all containers in the newly determined GHS format. The only exception to this is portable containers in which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer (ex. drugs dispensed by a pharmacy to a health care provided for direct consumption by a patient).
This means that all current products in storage will require relabeling according to the new GHS requirements. The revised Hazard Communication Standard (HCS) requires that all labels are printed with one of eight different pictograms inside of a red diamond border. These pictograms are only required on the label, however most new SDSs contain them as well. OSHA has not specified the size or type of material for these labels, only the required elements that each label must contain. Secondary containers can still use the existing HMIS labeling but must do that in addition to the GHS label. The HMIS label cannot conflict with the GHS label and employees must be trained on how to read and understand both labels.
Important to note is that these new GHS compliant labels do not replace the current Department of Transportation (DOT) labels that are still required under HazMat transportation regulations. Each hazardous material container must have a GHS compliant label for the product being transported. If that chemical is packaged within another package, the outermost package must contain the GHS label as well.
It is the employer's responsibility to maintain GHS compliant labels, however any company shipping products after June 1, 2016 with old labels are at risk for fines and penalties.
SafeTec is currently working with a few labeling vendors to build an API-based integration for more involved labeling needs. Our solution has canned labeling, which is satisfactory for many organizations. However, if label printing volume, complexity, hardware, and environment play are a factor in labeling needs, we often suggest going with something more robust. There are a variety of labeling vendors that provide hardware/software combinations that provide a wide array of label-printing features. These solutions often work splendidly, but lack data out of the box. This is where SafeTec can assist, by integrating with such a solution and populating it with (M)SDS data, specifically GHS (or HMIS/NFPA) in this case. SafeTec is currently testing pushing SafeTec GHS data to a third party labeling solution, and initial results are very positive and exciting! Just another way to set (M)SDS data free to be used for high value deliverables out of software products.