In less than a year, industrial product labels must be fully compliant with OSHAs new Hazard Communication Standard. Dont underestimate the work still to be done – or let myths and misconceptions color your decisions.
May 25 marked the two-year anniversary of when the U.S. Occupational Safety & Health Administration initially released a new Hazard Communication Standard and adopted the United Nations Globally Harmonized System of Classification and Labeling of Chemicals for the United States.
With that date, the employee training deadline has come and gone, leaving all of us less than a year to be fully GHS compliant. Yet, many companies remain reluctant to make labeling decisions until their old material safety data sheets are re-authored – and still, they may be underestimating the task at hand.
For the lubricants industry these tasks are taking longer than expected, and it seems the impact from additives has been the primary cause. Under the old OSHA regulations, many lubricant additives could be excluded when developing hazardous labeling content due to their concentration levels. But the new standards have lowered the threshold for what concentration levels must be reported, creating a need for additional disclosures on Safety Data Sheets and labels and therefore pushing a product into a hazardous classification.
This has come as a surprise to many lubricant companies. To further complicate the already complex process, other countries may have different GHS disclosure requirements for the concentration levels or hazards such as Environmental Hazards.
Whats the Holdup?
According to one global Top 50 petroleum and lubricants company we interviewed, staying abreast of each countrys GHS requirements, and determining how to deal with their different disclosure and language requirements for labels, were their greatest GHS implementation challenge currently and their greatest concern for the future.
Luc Sguin, Ph.D., founder of the SDS authoring services company KMK Regulatory Services, is a recognized regulatory expert on GHS and document compliance. Monitoring the impact on the industry, Sguin has identified four primary reasons companies are delaying their GHS implementation:
1) Concern about losing their competitive advantage by distributing a product with a GHS-compliant label that reflects a more hazardous product before competitors have done the same.
2) Possible modification of product formulations to reduce certain additive components to be below the disclosure threshold.
3) Further fact-gathering from additive suppliers related to products that were previously identified as a Trade Secret under OSHA, which may now require greater ingredient disclosure under GHS.
4) Creating one or multiple product-labeling formats based on other countries GHS disclosure requirements.
According to Sguin, these issues can be resolved by getting an SDS specialist involved early in the process.
More Complications
Beyond SDS authoring issues, weve noticed additional factors that explain why GHS implementation is taking longer than expected for petroleum and lubricant companies.
For one thing, the cost of qualified label material and color printing technology was greater than expected. As well, some existing labeling systems have become unmanageable due to company reorganizations, mergers and acquisitions. Companies are tackling this issue while they become GHS compliant, which complicates the initiative.
Finally, companies may be unprepared for the complexities regarding GHS label compliance. See Labeling Myths on page 32.
What Comes Next?
Now, its safe to say that most companies have identified how their new GHS-compliant SDS are going to be created, but there is still a question on everyones mind: What about labels? We see three important and imminent decisions that will need to be made.
First, how will you get the new SDS data into the label software? Best practice dictates that the SDS provider should provide GHS label-relevant data from the SDS. This data can be sent with an automatic handshake between the SDS system and the label software database located either on your company network or a web portal. Alternatively, the SDS label data can be manually uploaded to the label software database. For a graphic depiction of a web-based labeling system that utilizes the label-relevant SDS data to populate (automatically or manually) a label web portal, see the diagram on page 32. Such a web-based system provides the ability to centrally control all data (regulatory and non-regulatory) to be printed on a label in a 24/7 distributed environment.
Second, which printing technology will you use to get the red diamond frame on the label? For those companies that decide to implement color printing with their GHS implementation, there are primarily four technologies to choose from, and each has advantages and disadvantages. (See chart, page 34). Best practice suggests that matching the printer technology with your specific requirements (i.e., label print batch size, use of label automatic applicators, label printing and container storage environment, etc.) and with a qualified label material will save time, money and stress when finalizing your GHS implementation.
Third, what are your specific material and label image requirements for label production and application? Again, when it comes to GHS labeling, its a bit personal. Your specific requirements should drive the decisions about what will work best with or for your label printing solution.
To help you decide, weigh these critical success factors:
What are the durability requirements of the label and the printed label image?
What are the environmental conditions for the container at time of application, and during storage?
What material is the label being applied to on the container?
Does the label supplier understand the printer, and has it qualified the material for the printer?
Does the printer company view the label supplier as a qualified manufacturer?
For many, its easy to get caught up in the complexities and challenges of GHS implementation. All in all, its important to stay focused on your GHS compliance objectives and call for help when you need it. As the experts out here in the industry, our job is to make sure you are on board the compliance train. There is a light at the end of the GHS compliance tunnel. Just be sure that you are on the train heading towards compliance and not about to be run over by it. z
Myth: You must transition your label printers to color printers to comply with GHS requirements.
Truth: GHS requires a pictogram, which includes a red diamond frame and a black hazard symbol. An alternative to purchasing a color printer is to have your red diamond frames preprinted by your label supplier. Typically this requires multiple label stock formats or one stock preprinted with the maximum number of red diamond frames required. Then, utilizing a monochrome printer, the correct hazard symbol is printed inside the preprinted red diamond frame. If there are remaining blank red diamonds, they must be completely blacked out so as to block any view of the red diamond. Using preprinted red diamond frames may allow a company to retain existing monochrome printing systems.
However, many companies do not want to maintain a large number of different label formats. Transitioning to a color printing solution allows for label consolidation and fewer errors when printing labels. In addition, blocking out preprinted red diamond frames takes up valuable space on the label, could negatively impact the look of the label, and may cause confusion.
Myth: Any label will do.
Truth: Each label printer has unique requirements regarding the material processing and image durability. In addition, many other factors are involved in the application process, including speed, temperature, design, topcoating, etc. Label suppliers should be selected based on their ability to produce a qualified label for your specific printer.
Myth: Label and image durability are not impacted by a change in label printing technology.
Truth: The transition from a monochrome to a color label printer introduces many variables. One of the most important is the ability to print images durable enough for your specific requirements, including being transported. If your product is shipping over the international waterways, an International Maritime Dangerous Goods Act compliant label is required. The IMDG requirement says the label and the printed image must remain intact on the container, be readable, and the red diamond frame identifiable after floating in the ocean for 90 days. If IMDG compliance is required, your label supplier should be able to provide a BS5609 certification for your material and printer or test results validating the IMDG durability.
Myth: There is a significant difference in the total cost per printed label based on the color printing technology used.
Truth: Although there are significant differences in each cost variable (initial cost, printer service life, consumable cost and label media) for each printer, based on analyses using standard application criteria, the difference in total cost of a printed label may not be significant. Be careful when using published data about the total cost of a printed label as it can be biased and the assumptions used may not be relevant to your specific application.