- Email: [email protected]
Implementing the Hazard Communication Standard final rule: Lessons learned
RESEARCH ARTICLE
Implementing the Hazard Communication Standard [15_TD$IF]final rule: Lessons learned Changes to the Hazard Communication Standards (HCS) are bringing the United States into alignment with the Global Harmonization System (GHS). The new standard covers 43 million workers who handle hazardous chemicals in more than five million workplaces across the country. Forecasts predict that the implementation of these modifications to the HCS will prevent over 500 workplace injuries and illnesses, and 43 fatalities annually. This study, compiled through a collection and analysis of data provided by trainees who participated in the 2012 OSHA Susan Harwood training at the Rutgers School of Public Health, seeks to identify challenges and the effectiveness of this initiative. Survey data was obtained from a 21 question online survey 6–18 months post-training. In general, participants experienced several reoccurring challenges, including logistical difficulties of initiating a new and comprehensive training for all workers to the GHS changes, implementing GHS changes into their respective workplaces and receiving adequate management support and resources to initiate GHS efforts.
By Koshy Koshy, Michael Presutti, Mitchel A. Rosen
BACKGROUND/LITERATURE REVIEW
The sustained production and use of chemicals is vital to economic growth. Globally, the chemical industry accounts for more than $1.7 trillion per year business and affects many other related and ancillary industries. In the Koshy Koshy is a faculty member at the Rutgers School of Public Health, Department of Environmental and Occupational Health, 683 Hoes Lane West, Piscataway, New Jersey 08854, United States (Tel.: 732 235 9459; e-mail: [email protected]). Michael Presutti is an adjunct instructor at the School of Public Health, Office of Public Health Practice, 683 Hoes Lane West, Suite 110, Piscataway, New Jersey 08854, United States (e-mail: [email protected]). Mitchel A. Rosen is the director of the Office of Public Health Practice, Rutgers School of Public Health, 683 Hoes Lane West, Piscataway, New Jersey, United States (e-mail: [email protected]).
1871-5532 http://dx.doi.org/10.1016/j.jchas.2014.10.002
US, the chemical industry accounts for more than $450 billion in business, with exports surpassing $80 billion annually.1 Promulgated in 1983, the Hazard Communication Standard (HCS) has required employers to establish hazard communication programs for employees by means of labels on containers, material safety data sheets, and training programs. The implementation of a hazard communication program was then expected to ensure that all workers had a ‘‘right to know’’ the identities and hazards associated with of the chemicals they worked with, thereby inevitably reducing the likelihood of exposures.2 Occupational regulations require that workers, including public employees and emergency responders, be made aware of the hazards associated with various chemicals that they may handle or become exposed. An employer and or host employer must effectively train and communicate the physical and health – hazards associated with respective chemicals in the workplace. Through the regulatory ‘‘right to know’’ training obligations, an employer must ‘‘effectively’’ organize and communicate essential information on the hazardous chemicals and provide appropriate control measures. This ‘‘right to know’’ has evolved further to a ‘‘right to understand,’’ where
the Understanding of the nature and degree of chemical hazards inside of a worker’s working environment leads to more effective and practical control measures, which deter and lessen the likelihood of exposure. The United Nations Organization for Economic Cooperation and Development sponsored an initiative to establish a global system for hazard communication in 1992. The goal was to have a workable system in place, which included safety data sheets and easily understandable symbols, by 2000. The Occupational Safety and Health Administration (OSHA) issued final rule to revise the HCS (29CFR1910.1200) in March 2012. The HCS will now be aligned with the GHS of classification and labeling of chemicals. This update to the HCS will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. When completely implemented, the revised standard will improve the quality and consistency of hazard information in the workplace,3,4 making it safer for workers providing more understandable and consistent information on appropriate handling and safe use of hazardous chemicals. Three elements of the new GHS include (1) signal words (2) pictograms and (3) safety data sheets
ß Division of Chemical Health and Safety of the American Chemical Society Elsevier Inc. All rights reserved.
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Signal words of either WARNING or DANGER must appear on primary container labels. These terms are not interchangeable. DANGER identifies chemicals that present a relatively greater or more immediate hazard to the worker as opposed to WARNING which identifies a lesser degree of hazard. The Hazard Communication Standard (HCS) requires pictograms. The pictogram is determined by the chemical hazard classification. Workers are required to have access to the Safety Data Sheet (SDS) for the hazardous materials they work with at their site. Prior to the enactment of the GHS, there was no standard format for presenting information on the SDS. Common formats included an eight section document or the sixteen section ANSI format.5 The information required for the new 16-section format is presented in Table 1. Additionally, the word material is removed from its name and all hazard sheets are referred to as Safety Data Sheets (SDS). OSHA awarded a Susan Harwood Grant to the Rutgers School of Public Health (October 1, 2012–December 31, 2013) to disseminate knowledge and promote awareness of the changes to the Hazard Communication Standard related to GHS to the workers of Region II (New York and New Jersey). The
7.5-hour Nature of Chemical Hazards & Implications of GHS Applied to Industry course was developed as part of this program. This course was developed to assist business owners, managers, and others responsible for worker safety in understanding employer responsibility under the revised Hazard Communication Standard and to assist those with training responsibilities. Among the students recruited to participate in the training included OSHA Outreach Trainers authorized by Rutgers. Rutgers School of Public Health is one of 27 United States Department of Labor (USDOL) Occupational Safety and Health Administration (OSHA) Training Institute Education Centers (OTIEC). Trainees who successfully complete the Outreach Trainer courses at the OTIEC are authorized to offer the OSHA Outreach training. Health hazards, including Hazard Communication, is a required topic for all OSHA Outreach Training.6,7 Ten sessions of the 7.5-hour The Nature of Chemical Hazards & Implications of GHS Applied to Industry training were conducted for 220 participants. Users can access the training materials developed for this program at http://ophp.sph.rutgers.edu/ghs.zip
METHOD Study Design
Table 1. Sixteen-required sections of the revised safety data sheets (SDS).
1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16.
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Identification Hazard(s) identification Composition/information on ingredients First-aid measures Fire-fighting measures Accidental release measures Handling and storage Exposure control/personal protection Physical and chemical properties Stability and reactivity Toxicological information Ecological information Disposal considerations Transport information Regulatory information Other information
The Rutgers SPH administered an online survey to the 220 participants who completed the 7.5-hour The Nature of Chemical Hazards & Implications of GHS Applied to Industry training to identify the benefits as well as the challenges of implementing the GHS program. Researchers developed the survey at the Rutgers School of Public Health. The survey was approved by the Rutgers Institutional Review Board (IRB) and contained 21 questions (see attachments for a list of questions). Rutgers SPH implemented the survey using Surveymonkey.com, an online survey instrument, equipped with Skip Logic. Skip Logic provides the ability for the survey to be dynamic in the sense that only relevant questions are asked, based on previous response. If a question response is ‘no,’
then a follow-up question related to a ‘yes’ answer is skipped. The survey identifies how the training prepared participants to transition to GHS. They were queried on their efforts to train workers and the progress and experience of bringing their worksites into compliance with GHS. Data analysis yielded descriptive statistics about the survey participants, including state of employment, worker training experience and years of occupational safety and health experience.
RESULTS Participant Demographics
Surveys were distributed to all 220 participants who attended the 7.5-hour The Nature of Chemical Hazards & Implications of GHS Applied to Industry training, between February 18, 2013 and October 11, 2013 (8–16 months after completing the training). Ten email addresses were not valid, leaving a total of 210 participants in the study. A total of 110 completed the survey for a response rate of 52.4%. Of these respondents, 77 were employed in New Jersey, 27 in New York, one in Pennsylvania, three reported that they were employed in multiple states, and two skipped the question. Health and safety was the full time responsibility for 86 (78.2%), parttime for 21 (19.1%) and three reported that health and safety was not part of their responsibility. Consistent with changes to the Hazard Communication Standard that required vertical integration to all industry, the Rutgers Harwood program trained workers across all sectors. Of those who responded to the survey, 66 reported that they worked in general industry, 55 in construction, and three in maritime. Respondents were allowed to select more than one industry as some had cross functional responsibilities. The number of years the participants worked in safety and health is represented in Table 2. Disseminating GHS to the Workforce
Participants responded to a series of questions related to their efforts to provide GHS training after completing the Rutgers Harwood Program. The
Journal of Chemical Health & Safety, March/April 2015
Table 2. Participant years of experience in safety (n = 110).
Number of Years 0–5 6–10 11–15 16–20 21–25 More than 25
Respondents
Percentage of Respondents
18 20 15 16 29 12
16.4% 18.2% 13.6% 14.5% 26.4% 10.9%
Table 3. Participant responses to questions related to facilitating training and implanting GHS at the worksite.
Are you a health and safety trainer? Have you conducted a safety training that included GHS/Hazard Communication since completing the Rutgers GHS Program? Was your training part of an OSHA Outreach Training Were you able to incorporate the materials received from Rutgers Harwood GHS program into your training? Did you have difficulty conveying the GHS signal words to your trainees? Did your trainees identify any challenges to understanding Safety Data Sheets? goals included identifying the venue they used to conduct the training (stand-alone training or incorporated to another program), ability to incorporate the materials developed by Rutgers to their curriculum, and technical challenges they identified disseminating the information. Of the 110 survey respondents, 85 reported that health and safety training was among their job responsibilities. Seventy-three respondents reported conducting Hazard Communication/ GHS training since completing the Harwood program. Of these 73 trainers, 23 of them provided the Hazard Communication/GHS training as part of an OSHA Outreach Training. When asked if they were able to incorporate or enhance their training with the Rutgers GHS materials, all but five
Yes
No
Did Not Respond
85 73
25 12
0 25
23 62
45 5
42 43
5
62
43
8
59
43
responded ‘‘yes.’’ These results are presented in Table 3. The 73 respondents who reported that they conducted Hazard Communication/GHS Training were asked how many students they trained since completing the Rutgers Harwood Program (between February 18, 2013 and June 6, 2014). Sixty-seven of the respondents (six skipped the question) reported training a combined total of over 15,000 workers. The number of hours they dedicated to Hazard Communication/GHS in their training is listed in Table 4. The majority of them reported covering it in 1–2 hours (53.7%) of training. When an open-ended question ‘‘What were the major challenges you found in disseminating GHS to your students,’’ was posed to them, the
Table 4. Number of hours dedicated to the GHS/Hazard Communication at the training (n = 67).
Respondents Less than 1 hour 1–2 hours 2–3 hours 3–4 hours Greater than 4 hours
15 36 10 3 3
Journal of Chemical Health & Safety, March/April 2015
Percentage of Training 22.4% 53.7% 14.9% 4.5% 4.5%
following six reoccurring themes were identified by trainers as barriers to disseminating GHS information to their trainees: 1. Confusion with minimum training hours required for OSHA compliance 2. Acceptable documentation for proof of training 3. Confusion recognizing pictograms with similar symbols 4. Confusion between NFPA and GHS hazard classification 5. Difficulty conveying technical terms 6. Language barriers When asked if they started to implement the revised Hazard Communication Standard at their site, 65 of the participants responded ‘‘yes,’’ 36 ‘‘no’’ and nine skipped the question. From open-ended questions the following reoccurring themes were identified as challenges to implementing GHS. 1. Extended time period industry had to achieving full compliance with the standard leading to procrastination 2. Lack of awareness among vendors and contractors to the changes in the Hazard Communication Standard DISCUSSION Disseminating GHS to the Workforce Confusion with minimum training hours required for OSHA compliance
Respondents reported confusion with the number of hours needed to effectively deliver Hazard Communication/ GHS training. The confusion regarding the number of hours needed to comply with GHS training may have been the result of other mandatory hour-based trainings. The hazardous waste operations and emergency response training has been a requirement for hazardous waste site operations and cleanup workers since 1988.8 The number of hours needed to complete the training is in the title of such courses i.e., 40-hour Hazardous Waste Operations and Emergency Response (HAZWOPER) and the 8-hour Annual HAZWOPER Refresher. A recent New York City law, requiring all workers on
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major projects to have completed a10hour OSHA Outreach training, is another example of an hour-based training, and may have further bolstered a misunderstanding that there was an obligatory time consideration for HCS/GHS trainings.9,10 The HCS does not dictate a minimum time constraint on training but rather creates a more practical obligation; that the training be ‘‘effective.’’ Effective training would imply training employees to a point of saturation of course material with the anticipation that the training will achieve demonstrable observations in the work environment with trained workers utilizing the proscribed controls. Finding the appropriate length of class time (contact hours) necessary to adequately address the changes to the HCS for GHS is a challenge but should be gauged according to saturation and demonstrable field observations. The length of time needed to successfully complete any GHS training depends on the time needed to effectively disseminate workplace hazard specific information to the workers. Rutgers Harwood program emphasized that trainers gauge trainings by its respective effectiveness rather than a prescribed-time. Despite this knowledge, over 20% of the GHS trainers reported that they completed their respective training in less than one hour and many were able to incorporate the GHS changes into the health hazards sections of OSHA Outreach Training. Outreach Trainers can expand GHS further into a 10-hour General Industry class as an elective topic or in the 10-hour Construction training as an optional topic but anything more would have to be officially integrated into the OSHA Outreach course matrix, beyond the required seven hours as an optional or elective topic.11,12 Trainers also complied with the GHS training requirements by integrating it into their Process Safety Management (PSM) Refresher training.13 This was a good opportunity to meet both training requirements. As the phase-in period (see Figure 2 for schedule) for GHS will take several years, PSM training is a good opportunity to introduce as well as refresh and reinforce the fundamentals of the GHS in 2015 and 2016. 26
Acceptable documentation for proof of training
Confusion recognizing pictograms with similar symbols
Confusion regarding acceptable training documentation may have also been the result of past experiences. Through the OSHA Outreach Program workers receive Outreach Cards upon successful completion of their respective trainings.14 Very often the verification of training turns to the possession of a card or document. Employers were encouraged to document worker training by maintaining training sign-in sheets for their employee files as a means of qualifying employer training requirements under the HCS. It was also suggested in Harwood training classes that employers provide hard copy printed cards to workers to give them a sense of accomplishment and provide readily accessible proof of training.
Another obstacle some trainees found difficulty with was memorizing the different pictograms; in particular, several trainers expressed the difficulty trainees had distinguishing pictograms for oxidizing and flammable materials, as they are both represent an icon of a flame (Figure 1). We found the most effective strategy for helping workers remember the symbols was to give them comparative associated examples for each category. Instead of describing the oxidizer pictogram as a flame over a circle, we suggested in class the flame being described as being over the letter ‘‘O’’ standing for ‘‘Oxygen’’ and hence ‘‘O’’ prompting simple recall. It was also suggested the repetition and reviewing of symbols at tool box talks and during refresher
[(Figure_1)TD$IG]
Figure 1. Global Harmonization System (GHS) pictograms.
Journal of Chemical Health & Safety, March/April 2015
trainings was also apparently helpful triggering training mechanisms. Posting the symbols in areas where workers often convene worked as well.
of uniformity built-in to the changes; sometimes an aberration from the normal becomes more memorable because it stands out.
Confusion between NFPA and GHS hazard classification
Difficulty conveying technical terms
From the inception of the new HCS, OSHA remained flexible with existing standards. Employers are allowed to label containers using different identifying systems, as long as the information does not conflict with the revised HCS.15 Here the study’s data reflects the challenges with this policy. The hazard severity scale for GHS is opposite that of the National Fire Protection Association (NFPA) 704: Hazard Rating and the Hazardous Material Information System (HMIS) ‘‘hazard diamonds.’’ Under the NFPA, the degree of severity ranges from ‘‘0,’’ no unusual hazard, to ‘‘4,’’ extreme hazard, while the GHS scale of severity ranges from ‘‘1,’’ acute hazard, to ‘‘5,’’ not harmful. This inverse enumeration has caused some confusion among workers, since the new GHS HCS allows employers to use alternative labeling systems such as the NFPA providing the information supplied on labels are consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms. This chiasm exists in the revised HCS despite, the NFPA’s ratings are primarily intended for emergency responders while the GHS provides workers with the hazards associated with chemicals in the workplace under normal occupational conditions. Trainers lessened the confusion by showing examples of different chemicals and how they would be rated under NFPA and GHS alongside each other to demonstrate the dissimilarities. They also distinguished the NFPA categories by the unique colors of their respective hazards that offset the two standards.16 A good product to demonstrate the difference between GHS and NFPA classification is gasoline. It’s a Category 2 flammable liquid under GHS and a fire hazard 3 under NFPA.17 Explaining to trainees why flexibility was important to the HCS changes made the inverse severity enumerations between NFPA and GHS somewhat more palatable and may have become a learning tool in itself by highlighting the lack
Some trainers reported difficulty conveying technical terms such as ‘‘acutely toxic’’ to a mixed audience of workers with different levels of comprehension. An effective means of conveying technical information regarding a chemical’s hazard is to use analogies and examples to reinforce a basic understanding. During the Harwood Grant classes, Rutgers faculty sought to explain the dynamics behind complex chemical interactions by explaining the nature of groups of chemicals distinguished by their common hazard classifications. In this effort Rutgers faculty tried to answer trainees’ ‘‘how’’ and ‘‘why’’ questions.
[(Figure_2)TD$IG]
Effective Completion Date December 1, 2013
Recognizing a potential difficulty in conveying information about pH for an example, the use of illustrations such as those in Figure 3 was created to help build an underlying relationship between chemicals. The use of comparison between chemicals found in occupational settings versus common household chemicals made it easier for trainees to relate, especially when the exposures of these chemical hazards were described in the context of trainees inadvertently bringing contaminants into their home from work. Real life examples, such as describing that bases damage the skin, a lipid membrane, by emulsifying lipid-laden skin cells, just as basic dishwashing liquids break down grease, helped to demonstrate this point. Trainers also helped explain oxidation and free radicals in the context of how they are combated through the use
Requirement(s)
Who
Train employees on the new
Employers
label elements and safety data sheet (SDS) format. June 1, 2015
Compliance with all modified
Chemical manufacturers,
provisions of this final rule,
importers,
December 1, 2015
except: The Distributor shall not distributors and employers ship containers labeled by the chemical manufacturer or importer unless it is a GHS label
June 1, 2016
Update alternative workplace
Employers
labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Transition Period to the May comply with either 29 CFR
Chemical manufacturers,
effective completion
1910.1200 (the final standard),
importers, distributors, and
dates noted above
or the current standard, or both
employers
Figure 2. Phase-in period under the revised Hazard Communication Standard.
Journal of Chemical Health & Safety, March/April 2015
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[(Figure_3)TD$IG]
Figure 3. Relating pH to common items.
of vitamins in the human body. Many trainees had never put the two opposing concepts of oxidation and antioxidants alongside one another. Uniformly throughout the Harwood classes, after the concepts had been explained sideby-side, trainees would often intuitively guess at the common synonym for vitamins being ‘‘antioxidants.’’ For the purposes of chemical recognition, avoidance and prevention of exposure, connecting the terms of oxidation and antioxidants, trainees came to understand the hazards of free radicals in a simple and understandable manner. By connecting the hazards associated with chemical interactions, trainees became more astute at recognizing how chemical interactions can affect their health and wellbeing. As with all the chemical terminology, once participants understood the nature of the hazard, even at a fundamental or allegoric level, they will be more likely to avoid exposures and adhere to prescribed occupational controls. Language barriers
Trainers also noted certain challenges in conveying the new HCS/GHS alignment information to workers with limited English proficiency; this issue was especially prevalent in the construction industry. Although, the nine GHS pictograms help create a more universal means of communication and dissemination of chemical hazard warnings, they clearly do not cover the necessary degree of training required for the transfer of new knowledge. Much of this new HCS knowledge
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contains technical terminology with subtle nuances and meanings that a trainer could easily loose in translation. Words in the English language, such as ‘‘classifications’’ and ‘‘categories’’ can easily lead to confusion and misinterpretation. Again, the OSHA’s HCS provides guidance and directs employers to provide ‘‘effective training’’ that is measurable, demonstrable and predicated on a full transfer of knowledge to workers working with chemicals. As safety training increasingly requires language provisions for comprehension, additional resources must be dedicated to meeting this gap because it is simply not advisable to train such technical information in a non-native language and merely guess at comprehension. Implementation of the Revised Hazard Communication/GHS Program
At the time of the survey, many respondents reported that the main reason employers did not implement the new GHS harmonized standards into their respective workplaces already was they felt they had more time so delayed its initiation. They were able to achieve the first requirement of the revised standard by the required date of December 1, 2013, ‘‘train employees on the new label elements and safety data sheet (SDS) format.’’ The long duration industry had to achieve full compliance made it difficult for them to procure management commitment to allocate resources to a task that did not need to be completed before June 2016, two years away. As part of the curriculum inside of the
Harwood Grant training sessions, Rutgers faculty frequently encouraged employers to have an overlapped-transitional period where both new and former HCS’s were in place working side-by-side, where employers would, for example utilize the former Material Safety Data Sheets (MSDS’s) and the new GHS Safety Data Sheets (SDS’s) simultaneously. Such a transitional-period would allow employers to lessen the shock upon their business by gradually phasing one standard in place of another. Respondents also cited a general lack of awareness with vendors and contractors to the basic HCS, let alone GHS, as an impediment to fully executing the program. This is true to form and reflects sentiments outside of survey as well. The lack of a Hazard Communication Program was the second most frequently cited OSHA violations in FY 2013.18 This awareness-gap is possibly due to the difficulties launching any large-scale universal regulatory government requisite training affecting tens of millions of workers and stakeholders across all of industry all with limited federal resources. Respondents also cited difficulty in obtaining SDSs from their respective vendors for chemicals they commonly use or a schedule for when their suppliers were switching to the new GHS system for product labeling. Although it was completely tolerable at the time of the survey to allow the old labeling system to stay in place, many vendors were not aware of the changes that were quickly approaching. Workers were left in an awkward predicament of learning about the changes to the new HCS and not seeing the reality of these changes in their workplaces and not necessarily knowing in the foreseeable future when such changes would occur.
CONCLUSION
In general, according to feedback from survey, it appears industry tends to view the revised Hazard Communication Standard (HCS) as a very positive change as it will enable workers to more easily understand the hazards that chemicals pose in their workplaces. However, industry also seems to point to
Journal of Chemical Health & Safety, March/April 2015
predictable shortfalls and looks for more guidance and perhaps aids for HCS/GHS implementation from OSHA to effectively integrate GHS into their respective HCS compliance programs. A Best Practice Guideline Document needs to be available to industry, especially to small businesses that may not have necessary resources to update their HCS programs, to comply with the revised standard. Such a document should include template-based checklists to monitor and account for requisite training, an inventory matrix that pairs specific chemicals to specific employee training and catalogs for the compilation of site-specific SDS for, and prescribed facility inspections templates and generic protocol that employers can modify to suit their specific needs and vulnerabilities, forms and SDS request letters to suppliers. Since the lack of a Hazard Communication program is the second most cited OSHA violation, adding such an appendix or educational material may simultaneously increase compliance and address the new HCS requirements. Anecdotally, we found that those employers who received HCS/GHS training but never had a hazard communication program in place at the time
of training, especially in the construction industry; found that trainees more easily grasped the course’s content than those who were already using the older HCS. Presumably, this phenomenon occurred because the less-compliant trainees did not have to unlearn any dated material-it was all new to them. The first step toward GHS compliance is to train workers in the new changes. Many trainers incorporated HCS/GHS updates into their OSHA Outreach trainings or other safety initiatives and refreshers. This was a welcomed and refreshing feedback from the survey and points to creative ways to meet the training requirements. Adequate time needs to be dedicated to cover the three main parts of the revised standard (1) signal words (2) pictograms and (3) SDS. The amount of time needed for effectively communicating these new materials depends on individual workers’ aptitudes and respective job activities and exposures. Clearly employers need to better understand and emphasis the spirit of the HCS that necessitates effective training. Implementing the revised hazard communication system into workplaces is a more challenging process
than seemingly appears since employers also have to rely on external resources including vendors, chemical distributors and contractors to supply required HCS information such as SDS’s and proper labels. At the time of this study, the implementation date for manufacturers and distributors to reclassify chemicals and provide updated information was more than a year away. Yet optimistically, if the overwhelming response by these past participants to achieve compliance with the first part of the revised standard (Training Effective Date: December 1, 2013) is any indication, many of these employers should be able meet the next milestone, given the external resources. ACKNOWLEDGEMENT This study was funded by the United States Department of Labor (USDOL) Occupational Safety and Health Administration (OSHA) under the Susan Harwood Program: Grant # SH23527-12-6-F-34. The authors express their gratitude to the USDOL-OSHADirectorate of Training and Education (DTE) and the Region II OSHA for their continued support.
ATTACHMENT 1
Survey Questions Rutgers School of Public Health (SPH) Global Harmonization System (GHS) 1. Type of industry you work in? (Question #1) ____ General Industry _______ Construction _____________ Maritime 2. How long have you worked for your current? (Question #2) [Drop down menu to select number of years included] 3. State of employment?
_____ NY _____ NJ _____PA (Question #3)
______ other (Please specify) 4. Is safety and health part of your job responsibilities: (Question #4) ______ full time ____ part-time ______ not at all
Journal of Chemical Health & Safety, March/April 2015
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5. Are you a health and safety trainer? _____ yes
______ no (Question #5)
(no skip to question #6) 5a. Have you conducted GHS/Hazard Communication training? (Question #6) 5b. Was it part of an OSHA Outreach Training (10 or 30hr construction or General Industry? (Question #7) 5c. Were you able to incorporate the materials received from Rutgers School of Public Health Harwood Program into your training? (Question #8) 5d. How many workers did you train on GHS training as of today? (Question #9) 5e. How long was the GHS training you delivered to your students (hrs)? (Question #10) 5f. what were the major challenges you found in disseminating this information to your students? (Question #11) 5g. Did you have dificulty in conveying the GHS Signal words to your students? (Question #12) 5h. Please elaborate on any other challenges you may have had in conveying GHS to your students: ____________________________ (Question #13) 6. Did you cover Safety Data Sheets (SDS) as part of the training you offered? (Question #14) _______ no ______ yes (no skip to number 7) - Did your students identify any challenges to understanding SDS? (Question #15) - What were the challenges identiied? (Question #16) - How did you address these challenges? (Question #17) 7. Have you started implementing changes to labeling as per GHS at your worksite? (Question #18) ____________ yes _____________no Yes: What are the challenges you are facing while implementing GHS at your worksite? _______________________________________ (Question #19) 8. Please share any successes you’ve had from implementing the changes ________________________________________________ (Question #20) 9. We welcome your comments. Please let us know if you have any additional comments regarding the GHS program.
_______________________________________ (Question # 21)
End of Survey
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(OSHA). Outreach training program faq. https://www.osha.gov/dte/outreach/faqs.html [accessed July 2014]. U.S. Department of Labor, Occupational Safety & Health Administration (OSHA). Hazard communication proposed rule, request for comments. https://www.osha.gov/pls/oshaweb/ owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=21110 [accessed September 2014]. National Fire Protection Association (NFPA). Comparison of nfpa 704 and hazcom 2012 labels. http://www. nfpa.org/Assets/files/AboutTheCodes/ 704/NFPA704_HC2012_QCard.pdf [accessed July 2014]. Hess safety data sheet. Gasoline all grades. http://www.hess.com/docs/ussafety-data-sheets/gasoline-all-grades.pdf?sfvrsn=2 [accessed October 2014]. United States Department of LaborOccupational Safety and Health Administrations (OSHA). Top 10 most frequently cited standards. https:// www.osha.gov/Top_Ten_Standards. html [accessed July 2014].
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Implementing the Hazard Communication Standard [15_TD$IF]final rule: Lessons learned Changes to the Hazard Communication Standards (HCS) are bringing the United States into alignment with the Global Harmonization System (GHS). The new standard covers 43 million workers who handle hazardous chemicals in more than five million workplaces across the country. Forecasts predict that the implementation of these modifications to the HCS will prevent over 500 workplace injuries and illnesses, and 43 fatalities annually. This study, compiled through a collection and analysis of data provided by trainees who participated in the 2012 OSHA Susan Harwood training at the Rutgers School of Public Health, seeks to identify challenges and the effectiveness of this initiative. Survey data was obtained from a 21 question online survey 6–18 months post-training. In general, participants experienced several reoccurring challenges, including logistical difficulties of initiating a new and comprehensive training for all workers to the GHS changes, implementing GHS changes into their respective workplaces and receiving adequate management support and resources to initiate GHS efforts.
By Koshy Koshy, Michael Presutti, Mitchel A. Rosen
BACKGROUND/LITERATURE REVIEW
The sustained production and use of chemicals is vital to economic growth. Globally, the chemical industry accounts for more than $1.7 trillion per year business and affects many other related and ancillary industries. In the Koshy Koshy is a faculty member at the Rutgers School of Public Health, Department of Environmental and Occupational Health, 683 Hoes Lane West, Piscataway, New Jersey 08854, United States (Tel.: 732 235 9459; e-mail: [email protected]). Michael Presutti is an adjunct instructor at the School of Public Health, Office of Public Health Practice, 683 Hoes Lane West, Suite 110, Piscataway, New Jersey 08854, United States (e-mail: [email protected]). Mitchel A. Rosen is the director of the Office of Public Health Practice, Rutgers School of Public Health, 683 Hoes Lane West, Piscataway, New Jersey, United States (e-mail: [email protected]).
1871-5532 http://dx.doi.org/10.1016/j.jchas.2014.10.002
US, the chemical industry accounts for more than $450 billion in business, with exports surpassing $80 billion annually.1 Promulgated in 1983, the Hazard Communication Standard (HCS) has required employers to establish hazard communication programs for employees by means of labels on containers, material safety data sheets, and training programs. The implementation of a hazard communication program was then expected to ensure that all workers had a ‘‘right to know’’ the identities and hazards associated with of the chemicals they worked with, thereby inevitably reducing the likelihood of exposures.2 Occupational regulations require that workers, including public employees and emergency responders, be made aware of the hazards associated with various chemicals that they may handle or become exposed. An employer and or host employer must effectively train and communicate the physical and health – hazards associated with respective chemicals in the workplace. Through the regulatory ‘‘right to know’’ training obligations, an employer must ‘‘effectively’’ organize and communicate essential information on the hazardous chemicals and provide appropriate control measures. This ‘‘right to know’’ has evolved further to a ‘‘right to understand,’’ where
the Understanding of the nature and degree of chemical hazards inside of a worker’s working environment leads to more effective and practical control measures, which deter and lessen the likelihood of exposure. The United Nations Organization for Economic Cooperation and Development sponsored an initiative to establish a global system for hazard communication in 1992. The goal was to have a workable system in place, which included safety data sheets and easily understandable symbols, by 2000. The Occupational Safety and Health Administration (OSHA) issued final rule to revise the HCS (29CFR1910.1200) in March 2012. The HCS will now be aligned with the GHS of classification and labeling of chemicals. This update to the HCS will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. When completely implemented, the revised standard will improve the quality and consistency of hazard information in the workplace,3,4 making it safer for workers providing more understandable and consistent information on appropriate handling and safe use of hazardous chemicals. Three elements of the new GHS include (1) signal words (2) pictograms and (3) safety data sheets
ß Division of Chemical Health and Safety of the American Chemical Society Elsevier Inc. All rights reserved.
23
Signal words of either WARNING or DANGER must appear on primary container labels. These terms are not interchangeable. DANGER identifies chemicals that present a relatively greater or more immediate hazard to the worker as opposed to WARNING which identifies a lesser degree of hazard. The Hazard Communication Standard (HCS) requires pictograms. The pictogram is determined by the chemical hazard classification. Workers are required to have access to the Safety Data Sheet (SDS) for the hazardous materials they work with at their site. Prior to the enactment of the GHS, there was no standard format for presenting information on the SDS. Common formats included an eight section document or the sixteen section ANSI format.5 The information required for the new 16-section format is presented in Table 1. Additionally, the word material is removed from its name and all hazard sheets are referred to as Safety Data Sheets (SDS). OSHA awarded a Susan Harwood Grant to the Rutgers School of Public Health (October 1, 2012–December 31, 2013) to disseminate knowledge and promote awareness of the changes to the Hazard Communication Standard related to GHS to the workers of Region II (New York and New Jersey). The
7.5-hour Nature of Chemical Hazards & Implications of GHS Applied to Industry course was developed as part of this program. This course was developed to assist business owners, managers, and others responsible for worker safety in understanding employer responsibility under the revised Hazard Communication Standard and to assist those with training responsibilities. Among the students recruited to participate in the training included OSHA Outreach Trainers authorized by Rutgers. Rutgers School of Public Health is one of 27 United States Department of Labor (USDOL) Occupational Safety and Health Administration (OSHA) Training Institute Education Centers (OTIEC). Trainees who successfully complete the Outreach Trainer courses at the OTIEC are authorized to offer the OSHA Outreach training. Health hazards, including Hazard Communication, is a required topic for all OSHA Outreach Training.6,7 Ten sessions of the 7.5-hour The Nature of Chemical Hazards & Implications of GHS Applied to Industry training were conducted for 220 participants. Users can access the training materials developed for this program at http://ophp.sph.rutgers.edu/ghs.zip
METHOD Study Design
Table 1. Sixteen-required sections of the revised safety data sheets (SDS).
1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16.
24
Identification Hazard(s) identification Composition/information on ingredients First-aid measures Fire-fighting measures Accidental release measures Handling and storage Exposure control/personal protection Physical and chemical properties Stability and reactivity Toxicological information Ecological information Disposal considerations Transport information Regulatory information Other information
The Rutgers SPH administered an online survey to the 220 participants who completed the 7.5-hour The Nature of Chemical Hazards & Implications of GHS Applied to Industry training to identify the benefits as well as the challenges of implementing the GHS program. Researchers developed the survey at the Rutgers School of Public Health. The survey was approved by the Rutgers Institutional Review Board (IRB) and contained 21 questions (see attachments for a list of questions). Rutgers SPH implemented the survey using Surveymonkey.com, an online survey instrument, equipped with Skip Logic. Skip Logic provides the ability for the survey to be dynamic in the sense that only relevant questions are asked, based on previous response. If a question response is ‘no,’
then a follow-up question related to a ‘yes’ answer is skipped. The survey identifies how the training prepared participants to transition to GHS. They were queried on their efforts to train workers and the progress and experience of bringing their worksites into compliance with GHS. Data analysis yielded descriptive statistics about the survey participants, including state of employment, worker training experience and years of occupational safety and health experience.
RESULTS Participant Demographics
Surveys were distributed to all 220 participants who attended the 7.5-hour The Nature of Chemical Hazards & Implications of GHS Applied to Industry training, between February 18, 2013 and October 11, 2013 (8–16 months after completing the training). Ten email addresses were not valid, leaving a total of 210 participants in the study. A total of 110 completed the survey for a response rate of 52.4%. Of these respondents, 77 were employed in New Jersey, 27 in New York, one in Pennsylvania, three reported that they were employed in multiple states, and two skipped the question. Health and safety was the full time responsibility for 86 (78.2%), parttime for 21 (19.1%) and three reported that health and safety was not part of their responsibility. Consistent with changes to the Hazard Communication Standard that required vertical integration to all industry, the Rutgers Harwood program trained workers across all sectors. Of those who responded to the survey, 66 reported that they worked in general industry, 55 in construction, and three in maritime. Respondents were allowed to select more than one industry as some had cross functional responsibilities. The number of years the participants worked in safety and health is represented in Table 2. Disseminating GHS to the Workforce
Participants responded to a series of questions related to their efforts to provide GHS training after completing the Rutgers Harwood Program. The
Journal of Chemical Health & Safety, March/April 2015
Table 2. Participant years of experience in safety (n = 110).
Number of Years 0–5 6–10 11–15 16–20 21–25 More than 25
Respondents
Percentage of Respondents
18 20 15 16 29 12
16.4% 18.2% 13.6% 14.5% 26.4% 10.9%
Table 3. Participant responses to questions related to facilitating training and implanting GHS at the worksite.
Are you a health and safety trainer? Have you conducted a safety training that included GHS/Hazard Communication since completing the Rutgers GHS Program? Was your training part of an OSHA Outreach Training Were you able to incorporate the materials received from Rutgers Harwood GHS program into your training? Did you have difficulty conveying the GHS signal words to your trainees? Did your trainees identify any challenges to understanding Safety Data Sheets? goals included identifying the venue they used to conduct the training (stand-alone training or incorporated to another program), ability to incorporate the materials developed by Rutgers to their curriculum, and technical challenges they identified disseminating the information. Of the 110 survey respondents, 85 reported that health and safety training was among their job responsibilities. Seventy-three respondents reported conducting Hazard Communication/ GHS training since completing the Harwood program. Of these 73 trainers, 23 of them provided the Hazard Communication/GHS training as part of an OSHA Outreach Training. When asked if they were able to incorporate or enhance their training with the Rutgers GHS materials, all but five
Yes
No
Did Not Respond
85 73
25 12
0 25
23 62
45 5
42 43
5
62
43
8
59
43
responded ‘‘yes.’’ These results are presented in Table 3. The 73 respondents who reported that they conducted Hazard Communication/GHS Training were asked how many students they trained since completing the Rutgers Harwood Program (between February 18, 2013 and June 6, 2014). Sixty-seven of the respondents (six skipped the question) reported training a combined total of over 15,000 workers. The number of hours they dedicated to Hazard Communication/GHS in their training is listed in Table 4. The majority of them reported covering it in 1–2 hours (53.7%) of training. When an open-ended question ‘‘What were the major challenges you found in disseminating GHS to your students,’’ was posed to them, the
Table 4. Number of hours dedicated to the GHS/Hazard Communication at the training (n = 67).
Respondents Less than 1 hour 1–2 hours 2–3 hours 3–4 hours Greater than 4 hours
15 36 10 3 3
Journal of Chemical Health & Safety, March/April 2015
Percentage of Training 22.4% 53.7% 14.9% 4.5% 4.5%
following six reoccurring themes were identified by trainers as barriers to disseminating GHS information to their trainees: 1. Confusion with minimum training hours required for OSHA compliance 2. Acceptable documentation for proof of training 3. Confusion recognizing pictograms with similar symbols 4. Confusion between NFPA and GHS hazard classification 5. Difficulty conveying technical terms 6. Language barriers When asked if they started to implement the revised Hazard Communication Standard at their site, 65 of the participants responded ‘‘yes,’’ 36 ‘‘no’’ and nine skipped the question. From open-ended questions the following reoccurring themes were identified as challenges to implementing GHS. 1. Extended time period industry had to achieving full compliance with the standard leading to procrastination 2. Lack of awareness among vendors and contractors to the changes in the Hazard Communication Standard DISCUSSION Disseminating GHS to the Workforce Confusion with minimum training hours required for OSHA compliance
Respondents reported confusion with the number of hours needed to effectively deliver Hazard Communication/ GHS training. The confusion regarding the number of hours needed to comply with GHS training may have been the result of other mandatory hour-based trainings. The hazardous waste operations and emergency response training has been a requirement for hazardous waste site operations and cleanup workers since 1988.8 The number of hours needed to complete the training is in the title of such courses i.e., 40-hour Hazardous Waste Operations and Emergency Response (HAZWOPER) and the 8-hour Annual HAZWOPER Refresher. A recent New York City law, requiring all workers on
25
major projects to have completed a10hour OSHA Outreach training, is another example of an hour-based training, and may have further bolstered a misunderstanding that there was an obligatory time consideration for HCS/GHS trainings.9,10 The HCS does not dictate a minimum time constraint on training but rather creates a more practical obligation; that the training be ‘‘effective.’’ Effective training would imply training employees to a point of saturation of course material with the anticipation that the training will achieve demonstrable observations in the work environment with trained workers utilizing the proscribed controls. Finding the appropriate length of class time (contact hours) necessary to adequately address the changes to the HCS for GHS is a challenge but should be gauged according to saturation and demonstrable field observations. The length of time needed to successfully complete any GHS training depends on the time needed to effectively disseminate workplace hazard specific information to the workers. Rutgers Harwood program emphasized that trainers gauge trainings by its respective effectiveness rather than a prescribed-time. Despite this knowledge, over 20% of the GHS trainers reported that they completed their respective training in less than one hour and many were able to incorporate the GHS changes into the health hazards sections of OSHA Outreach Training. Outreach Trainers can expand GHS further into a 10-hour General Industry class as an elective topic or in the 10-hour Construction training as an optional topic but anything more would have to be officially integrated into the OSHA Outreach course matrix, beyond the required seven hours as an optional or elective topic.11,12 Trainers also complied with the GHS training requirements by integrating it into their Process Safety Management (PSM) Refresher training.13 This was a good opportunity to meet both training requirements. As the phase-in period (see Figure 2 for schedule) for GHS will take several years, PSM training is a good opportunity to introduce as well as refresh and reinforce the fundamentals of the GHS in 2015 and 2016. 26
Acceptable documentation for proof of training
Confusion recognizing pictograms with similar symbols
Confusion regarding acceptable training documentation may have also been the result of past experiences. Through the OSHA Outreach Program workers receive Outreach Cards upon successful completion of their respective trainings.14 Very often the verification of training turns to the possession of a card or document. Employers were encouraged to document worker training by maintaining training sign-in sheets for their employee files as a means of qualifying employer training requirements under the HCS. It was also suggested in Harwood training classes that employers provide hard copy printed cards to workers to give them a sense of accomplishment and provide readily accessible proof of training.
Another obstacle some trainees found difficulty with was memorizing the different pictograms; in particular, several trainers expressed the difficulty trainees had distinguishing pictograms for oxidizing and flammable materials, as they are both represent an icon of a flame (Figure 1). We found the most effective strategy for helping workers remember the symbols was to give them comparative associated examples for each category. Instead of describing the oxidizer pictogram as a flame over a circle, we suggested in class the flame being described as being over the letter ‘‘O’’ standing for ‘‘Oxygen’’ and hence ‘‘O’’ prompting simple recall. It was also suggested the repetition and reviewing of symbols at tool box talks and during refresher
[(Figure_1)TD$IG]
Figure 1. Global Harmonization System (GHS) pictograms.
Journal of Chemical Health & Safety, March/April 2015
trainings was also apparently helpful triggering training mechanisms. Posting the symbols in areas where workers often convene worked as well.
of uniformity built-in to the changes; sometimes an aberration from the normal becomes more memorable because it stands out.
Confusion between NFPA and GHS hazard classification
Difficulty conveying technical terms
From the inception of the new HCS, OSHA remained flexible with existing standards. Employers are allowed to label containers using different identifying systems, as long as the information does not conflict with the revised HCS.15 Here the study’s data reflects the challenges with this policy. The hazard severity scale for GHS is opposite that of the National Fire Protection Association (NFPA) 704: Hazard Rating and the Hazardous Material Information System (HMIS) ‘‘hazard diamonds.’’ Under the NFPA, the degree of severity ranges from ‘‘0,’’ no unusual hazard, to ‘‘4,’’ extreme hazard, while the GHS scale of severity ranges from ‘‘1,’’ acute hazard, to ‘‘5,’’ not harmful. This inverse enumeration has caused some confusion among workers, since the new GHS HCS allows employers to use alternative labeling systems such as the NFPA providing the information supplied on labels are consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms. This chiasm exists in the revised HCS despite, the NFPA’s ratings are primarily intended for emergency responders while the GHS provides workers with the hazards associated with chemicals in the workplace under normal occupational conditions. Trainers lessened the confusion by showing examples of different chemicals and how they would be rated under NFPA and GHS alongside each other to demonstrate the dissimilarities. They also distinguished the NFPA categories by the unique colors of their respective hazards that offset the two standards.16 A good product to demonstrate the difference between GHS and NFPA classification is gasoline. It’s a Category 2 flammable liquid under GHS and a fire hazard 3 under NFPA.17 Explaining to trainees why flexibility was important to the HCS changes made the inverse severity enumerations between NFPA and GHS somewhat more palatable and may have become a learning tool in itself by highlighting the lack
Some trainers reported difficulty conveying technical terms such as ‘‘acutely toxic’’ to a mixed audience of workers with different levels of comprehension. An effective means of conveying technical information regarding a chemical’s hazard is to use analogies and examples to reinforce a basic understanding. During the Harwood Grant classes, Rutgers faculty sought to explain the dynamics behind complex chemical interactions by explaining the nature of groups of chemicals distinguished by their common hazard classifications. In this effort Rutgers faculty tried to answer trainees’ ‘‘how’’ and ‘‘why’’ questions.
[(Figure_2)TD$IG]
Effective Completion Date December 1, 2013
Recognizing a potential difficulty in conveying information about pH for an example, the use of illustrations such as those in Figure 3 was created to help build an underlying relationship between chemicals. The use of comparison between chemicals found in occupational settings versus common household chemicals made it easier for trainees to relate, especially when the exposures of these chemical hazards were described in the context of trainees inadvertently bringing contaminants into their home from work. Real life examples, such as describing that bases damage the skin, a lipid membrane, by emulsifying lipid-laden skin cells, just as basic dishwashing liquids break down grease, helped to demonstrate this point. Trainers also helped explain oxidation and free radicals in the context of how they are combated through the use
Requirement(s)
Who
Train employees on the new
Employers
label elements and safety data sheet (SDS) format. June 1, 2015
Compliance with all modified
Chemical manufacturers,
provisions of this final rule,
importers,
December 1, 2015
except: The Distributor shall not distributors and employers ship containers labeled by the chemical manufacturer or importer unless it is a GHS label
June 1, 2016
Update alternative workplace
Employers
labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Transition Period to the May comply with either 29 CFR
Chemical manufacturers,
effective completion
1910.1200 (the final standard),
importers, distributors, and
dates noted above
or the current standard, or both
employers
Figure 2. Phase-in period under the revised Hazard Communication Standard.
Journal of Chemical Health & Safety, March/April 2015
27
[(Figure_3)TD$IG]
Figure 3. Relating pH to common items.
of vitamins in the human body. Many trainees had never put the two opposing concepts of oxidation and antioxidants alongside one another. Uniformly throughout the Harwood classes, after the concepts had been explained sideby-side, trainees would often intuitively guess at the common synonym for vitamins being ‘‘antioxidants.’’ For the purposes of chemical recognition, avoidance and prevention of exposure, connecting the terms of oxidation and antioxidants, trainees came to understand the hazards of free radicals in a simple and understandable manner. By connecting the hazards associated with chemical interactions, trainees became more astute at recognizing how chemical interactions can affect their health and wellbeing. As with all the chemical terminology, once participants understood the nature of the hazard, even at a fundamental or allegoric level, they will be more likely to avoid exposures and adhere to prescribed occupational controls. Language barriers
Trainers also noted certain challenges in conveying the new HCS/GHS alignment information to workers with limited English proficiency; this issue was especially prevalent in the construction industry. Although, the nine GHS pictograms help create a more universal means of communication and dissemination of chemical hazard warnings, they clearly do not cover the necessary degree of training required for the transfer of new knowledge. Much of this new HCS knowledge
28
contains technical terminology with subtle nuances and meanings that a trainer could easily loose in translation. Words in the English language, such as ‘‘classifications’’ and ‘‘categories’’ can easily lead to confusion and misinterpretation. Again, the OSHA’s HCS provides guidance and directs employers to provide ‘‘effective training’’ that is measurable, demonstrable and predicated on a full transfer of knowledge to workers working with chemicals. As safety training increasingly requires language provisions for comprehension, additional resources must be dedicated to meeting this gap because it is simply not advisable to train such technical information in a non-native language and merely guess at comprehension. Implementation of the Revised Hazard Communication/GHS Program
At the time of the survey, many respondents reported that the main reason employers did not implement the new GHS harmonized standards into their respective workplaces already was they felt they had more time so delayed its initiation. They were able to achieve the first requirement of the revised standard by the required date of December 1, 2013, ‘‘train employees on the new label elements and safety data sheet (SDS) format.’’ The long duration industry had to achieve full compliance made it difficult for them to procure management commitment to allocate resources to a task that did not need to be completed before June 2016, two years away. As part of the curriculum inside of the
Harwood Grant training sessions, Rutgers faculty frequently encouraged employers to have an overlapped-transitional period where both new and former HCS’s were in place working side-by-side, where employers would, for example utilize the former Material Safety Data Sheets (MSDS’s) and the new GHS Safety Data Sheets (SDS’s) simultaneously. Such a transitional-period would allow employers to lessen the shock upon their business by gradually phasing one standard in place of another. Respondents also cited a general lack of awareness with vendors and contractors to the basic HCS, let alone GHS, as an impediment to fully executing the program. This is true to form and reflects sentiments outside of survey as well. The lack of a Hazard Communication Program was the second most frequently cited OSHA violations in FY 2013.18 This awareness-gap is possibly due to the difficulties launching any large-scale universal regulatory government requisite training affecting tens of millions of workers and stakeholders across all of industry all with limited federal resources. Respondents also cited difficulty in obtaining SDSs from their respective vendors for chemicals they commonly use or a schedule for when their suppliers were switching to the new GHS system for product labeling. Although it was completely tolerable at the time of the survey to allow the old labeling system to stay in place, many vendors were not aware of the changes that were quickly approaching. Workers were left in an awkward predicament of learning about the changes to the new HCS and not seeing the reality of these changes in their workplaces and not necessarily knowing in the foreseeable future when such changes would occur.
CONCLUSION
In general, according to feedback from survey, it appears industry tends to view the revised Hazard Communication Standard (HCS) as a very positive change as it will enable workers to more easily understand the hazards that chemicals pose in their workplaces. However, industry also seems to point to
Journal of Chemical Health & Safety, March/April 2015
predictable shortfalls and looks for more guidance and perhaps aids for HCS/GHS implementation from OSHA to effectively integrate GHS into their respective HCS compliance programs. A Best Practice Guideline Document needs to be available to industry, especially to small businesses that may not have necessary resources to update their HCS programs, to comply with the revised standard. Such a document should include template-based checklists to monitor and account for requisite training, an inventory matrix that pairs specific chemicals to specific employee training and catalogs for the compilation of site-specific SDS for, and prescribed facility inspections templates and generic protocol that employers can modify to suit their specific needs and vulnerabilities, forms and SDS request letters to suppliers. Since the lack of a Hazard Communication program is the second most cited OSHA violation, adding such an appendix or educational material may simultaneously increase compliance and address the new HCS requirements. Anecdotally, we found that those employers who received HCS/GHS training but never had a hazard communication program in place at the time
of training, especially in the construction industry; found that trainees more easily grasped the course’s content than those who were already using the older HCS. Presumably, this phenomenon occurred because the less-compliant trainees did not have to unlearn any dated material-it was all new to them. The first step toward GHS compliance is to train workers in the new changes. Many trainers incorporated HCS/GHS updates into their OSHA Outreach trainings or other safety initiatives and refreshers. This was a welcomed and refreshing feedback from the survey and points to creative ways to meet the training requirements. Adequate time needs to be dedicated to cover the three main parts of the revised standard (1) signal words (2) pictograms and (3) SDS. The amount of time needed for effectively communicating these new materials depends on individual workers’ aptitudes and respective job activities and exposures. Clearly employers need to better understand and emphasis the spirit of the HCS that necessitates effective training. Implementing the revised hazard communication system into workplaces is a more challenging process
than seemingly appears since employers also have to rely on external resources including vendors, chemical distributors and contractors to supply required HCS information such as SDS’s and proper labels. At the time of this study, the implementation date for manufacturers and distributors to reclassify chemicals and provide updated information was more than a year away. Yet optimistically, if the overwhelming response by these past participants to achieve compliance with the first part of the revised standard (Training Effective Date: December 1, 2013) is any indication, many of these employers should be able meet the next milestone, given the external resources. ACKNOWLEDGEMENT This study was funded by the United States Department of Labor (USDOL) Occupational Safety and Health Administration (OSHA) under the Susan Harwood Program: Grant # SH23527-12-6-F-34. The authors express their gratitude to the USDOL-OSHADirectorate of Training and Education (DTE) and the Region II OSHA for their continued support.
ATTACHMENT 1
Survey Questions Rutgers School of Public Health (SPH) Global Harmonization System (GHS) 1. Type of industry you work in? (Question #1) ____ General Industry _______ Construction _____________ Maritime 2. How long have you worked for your current? (Question #2) [Drop down menu to select number of years included] 3. State of employment?
_____ NY _____ NJ _____PA (Question #3)
______ other (Please specify) 4. Is safety and health part of your job responsibilities: (Question #4) ______ full time ____ part-time ______ not at all
Journal of Chemical Health & Safety, March/April 2015
29
5. Are you a health and safety trainer? _____ yes
______ no (Question #5)
(no skip to question #6) 5a. Have you conducted GHS/Hazard Communication training? (Question #6) 5b. Was it part of an OSHA Outreach Training (10 or 30hr construction or General Industry? (Question #7) 5c. Were you able to incorporate the materials received from Rutgers School of Public Health Harwood Program into your training? (Question #8) 5d. How many workers did you train on GHS training as of today? (Question #9) 5e. How long was the GHS training you delivered to your students (hrs)? (Question #10) 5f. what were the major challenges you found in disseminating this information to your students? (Question #11) 5g. Did you have dificulty in conveying the GHS Signal words to your students? (Question #12) 5h. Please elaborate on any other challenges you may have had in conveying GHS to your students: ____________________________ (Question #13) 6. Did you cover Safety Data Sheets (SDS) as part of the training you offered? (Question #14) _______ no ______ yes (no skip to number 7) - Did your students identify any challenges to understanding SDS? (Question #15) - What were the challenges identiied? (Question #16) - How did you address these challenges? (Question #17) 7. Have you started implementing changes to labeling as per GHS at your worksite? (Question #18) ____________ yes _____________no Yes: What are the challenges you are facing while implementing GHS at your worksite? _______________________________________ (Question #19) 8. Please share any successes you’ve had from implementing the changes ________________________________________________ (Question #20) 9. We welcome your comments. Please let us know if you have any additional comments regarding the GHS program.
_______________________________________ (Question # 21)
End of Survey
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