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Tips to Ensure GHS Compliance for Chemical Container Labels
K-12 school and college facility managers in charge of safety, purchasing, administration or operations would be wise to ensure that their labels on containers ranging from barrels to spray bottles for chemical formulations such as cleaners, sanitizers, paints, solvents and sealants are "Globally Harmonized System" (GHS) compliant.
While not all schools and colleges are covered by OSHA, all administrators need to know that GHS was established by the United Nations to create a unified system for identifying and communicating hazardous chemicals in order to keep facilities and their employees safe. All chemical manufacturers and distributors must now be using GHS labels, so school and college administrators must understand the GHS system.
In the U.S., OSHA set a June 2015 deadline for chemical manufacturers to use GHS-compliant labels, followed by a December 2015 deadline for distributors and June 2016 deadline for end users. Employers with hazardous chemicals in the workplace, for their part, must ensure they have safety data sheets and labels for their exposed workers, and must train them to handle the chemicals properly.
GHS label compliance is required of end users even for chemical formulations bought in bulk containers, such as barrels of sanitizer or cleaning solutions transferred to smaller "down-packed" containers, such as spray bottles, for portable use. Such formulations include common compounds that can be dangerous or deadly in the wrong combination, such as bleach and ammonia or flammable paints and oxidizers.
"For any stragglers who are not GHS label compliant, OSHA fines and penalties have gone up 78 percent," says Mark Howell, owner of Howell Safety & Training Solutions, a Jonesboro, AR-based safety and risk management consulting company. "The maximum fine rose from $7,000 to $12,471 per violation, and for more serious issues, from $70,000 to $124,709 per violation."
Improving safety for the school and college workers who handle cleaning supplies and other chemicals is easier than it seems. Educational administrators and EHS professionals that are still challenged by GHS label compliance would do well to follow six tips for even smaller "down-packed" chemical container labeling.
1. Have GHS-compliant safety data sheets and labels and train workers to handle hazardous chemicals properly. On each GHS label, six items of data are required: Product Name or Identifier, Hazard Statement, Signal Word, GHS Pictogram symbols, Precautionary Statement and Supplier Information.
Instead of the familiar black-and-white pictogram symbols previously used in safety labeling, GHS labels now require pictogram symbols that convey hazard information with a red diamond border.
"Conveying GHS label information clearly is critical, not only for compliance but also for safety," says Howell. "For instance, mixing ammonia cleaner with bleach can create dangerous fumes. Commonly used chemicals used in a school environment, if improperly used, can have catastrophic results."
2. Label all secondary containers. If a chemical is supplied to the workplace with a GHS label, it must be maintained. If the chemical is transferred to a secondary container, such as a tank or spray bottle that stays in the workplace, employers must label it with information from the original GHS shipping label or safety data sheet.
"Because of the volume of cleaning supplies used to maintain K–12 schools and college campuses, a lot of chemicals are purchased in bulk and must be properly labeled to GHS requirements in secondary containers like spray bottles," says Howell.
He adds, "An important benefit of the GHS labeling system to school and college campuses is how it can help improve safety. The pictogram symbols help to convey danger information quickly to those that may be exposed and not trained in the use of the chemicals. A child can quickly recognize the skull and crossbones or the flame symbol and identify that this is a dangerous chemical."
3. Save on printing with durable label options on demand. Implementing GHS labeling can seem daunting to end users, but does not have to be. Many are turning to flexible, lower cost options, such as commercial/industrial-grade labels that allow printing durable GHS labels on demand with existing laser printers and certain inkjet printers.
Unlike standard labels, these labels are used in harsh environments like restaurants, hotels, warehouses and manufacturing facilities so must be very durable and able to withstand exposure to chemicals, abrasion, tearing, moisture, sunlight and extreme temperatures.
"Software with modifiable templates allows you to quickly create GHS labels in the quantities you need, at the time you need them," says Howell. "You can quickly print a single label for a spray bottle in a classroom or dozens for a college campus. You can also save your labels so you don't have to recreate them every time."
4. Meet rugged GHS commercial requirements to stay compliant. The challenge is that to be GHS compliant, labels must stay reliably affixed without fading or becoming unreadable despite harsh indoor or outdoor conditions including exposure to chemicals, moisture and spills.
Some label companies have designed their labels to meet rigorous GHS requirements. Some GHS labels are chemical resistant, tear resistant, abrasion resistant and constructed with a marine-grade adhesive that is waterproof and passes a 90-day seawater submersion adhesion test.
Unlike typical labels, which crack and harden in harsh conditions, the GHS labels are UV resistant with 2+ years of outdoor UV life. They are also temperature resistant, can be applied as low as 10°F, and used between -20°F to 220°F when printed from color laser printers or -40°F to 300°F when printed from pigment-based inkjet printers.
"Commercial grade labels will help schools and colleges stay GHS compliant as end users of chemical formulations," says Howell. "They are designed to withstand harsh indoor or outdoor conditions, where spills, moisture, and sunlight may be common. A faded or illegible label is the same as no label at all. That is why it is important to use durable label systems. But more importantly, labels convey important safety information to end users and others who are potentially at risk if chemicals are used improperly."
5. Take advantage of free label-printing software. Some companies provide such GHS-compliant label software at no cost. A Design & Print GHS Wizard allows employees to create and print their own GHS and HMIS labels from predesigned templates. They can create on-demand labels step-by-step at their desk. Most employees find such a process intuitive, since it resembles creating an office document from predesigned templates.
The software must include the pictograms and GHS-compliant statements needed for GHS labeling, allow customizable text and insertion of company/school logo or other images, generate 18 types of barcodes and offer a sequential numbering feature to add lot numbers or other variable data.
GHS labels can be securely saved online or to a computer. The software should be capable of printing other safety labels as well.
6. Choose GHS labels that work with the full range of container sizes and container surface types. GHS labels are available in a range of sizes to fit drums, totes, pails, cans, jugs, containers and even small bottles. They can be applied to a variety of surfaces such as metal, plastic, glass, ceramic, polycarbonate, painted surfaces and more. Similar to office labels, the GHS labels offer easy-peel, smudge-free and jam-free capabilities.
For labeling that requires the durability of extra lamination, self-laminating ID labels are available which come with a clear laminate so no lamination machine or additional layer of tape is needed. The material is UV- and water-resistant and resists scuffing, tearing and smudging, making the labels suitable around moist, humid or wet environments.
"Universal GHS label compliance will improve school and college campus safety by minimizing chemical misidentification and mishandling risk," concludes Howell. "Keep in mind, however, that GHS labeling falls under a United Nations standard that OSHA follows, so GHS updates will now occur about every four years. School and university administrators will want to work with a GHS label provider and perhaps a consultant that will keep them up to date with these changes."
Colwin Chan is the senior product manager for Avery Safety & Facilities Solutions, a division of the Avery Products Corporation. He spearheads the development of innovative labeling and identification products for GHS, safety and industrial needs in the workplace.