Regulations Specs & Testing

The Sticking Point


With the deadlines for Globally Harmonized System (GHS) label compliance now past for chemical manufacturers, distributors and end users, OSHA has some stiff fines planned for those not yet with the program.
For any stragglers who are not GHS label compliant, OSHA fines and penalties [were] expected to go up 80 percent this summer, reminded Mark Howell, owner of Howell Safety and Training Solutions, a Jonesboro, Arkansas-based safety and risk management consulting company. By August 1, the maximum fine was expected to rise from $7,000 per violation to $12,600 per violation, and for more serious issues from $70,000 to $127,000 per violation.
Distributors and end users who may not yet be fully GHS label compliant after the most recent June 1, 2016, deadline, or who may want to streamline their compliance process, will find that easy GHS labeling options can cut the complexity as well as make production safer. For end users, GHS compliance is required for chemical formulations purchased in bulk containers for cost savings, such as barrels of industrial cleaner that are transferred to smaller down-packed containers, like spray bottles, for portable use.
Containers requiring GHS-compliant labeling can vary in size from 55-gallon drums down to little test vials. In an industrial setting, chemical formulations that could require GHS labeling range from lubricants, greases, cutting oils and rust removers to industrial primers, coatings and sealants to acid, alkaline and solvent based cleaners to degreasers, surfactants, disinfectants and sanitizers. The list goes on and on.
Distributors and end users that are still challenged by GHS label compliance would do well to emulate a metal manufacturer that recently became compliant while improving safety on its production line. When this large metal supply service center in Ohio sought GHS label compliance for down-packed secondary container labeling, it proactively sought a solution.
According to David Heberling, quality metallurgist and safety manager at the metal service center, down-packing was necessary each time it transferred material from 55-gallon drums into smaller containers equipped with spray nozzles. The end-user applications involve spraying oils, solvents and lubricants onto product surfaces and into production line equipment that produces flat-rolled steel, in coils and cut lengths.
Label durability is important to us, so we turned to Averys UltraDuty GHS Chemical Labels, said Heberling.
While Avery has been a well-known label brand in the office market for decades, these GHS labels – unlike typical labels – are industrial-grade labels designed to be chemical resistant, tear resistant and abrasion resistant; theyre also constructed with a marine-grade adhesive that is waterproof and passes a 90-day seawater submersion adhesion test.
Just as important to Heberling, if not more so, was the ease of use of the label-printing software, available from the companys website at no cost. The companys Design & Print GHS Wizard allowed employees at the company to create and print their own GHS and Canadian Hazardous Materials Identification System (HMIS) labels from pre-designed templates. They can create on-demand labels step-by-step at their desk, as well as create GHS and HMIS hybrid labels capable of satisfying both U.S. and Canadian hazard communication systems. Most employees find such a process intuitive, since it resembles creating an office document from pre-designed templates.
The software includes the pictograms and GHS compliant statements needed for proper GHS labeling; allows customizable text; insertion of company logo or other images; generation of 18 types of barcodes; and a sequential numbering feature to add lot numbers or other variable data.
What I really needed was the chemical name, hazards, pictograms and precautions for internal company use, said Heberling. I like that when I entered the CAS number for the main chemical ingredient, from the Safety Data Sheet, the software filled these in and allowed me to modify them to suit our situation as appropriate. Most of the work was done for me.
No download is required since the software operates from Averys website, and GHS, HMIS and NFPA labels (for fire precautions) can be securely saved online or to a computer. The software is also capable of printing other safety labels such as OSHA, ANSI and DOT labels.
The ability to convey needed GHS label info clearly, as well as combine it with other systems like HMIS and NFPA can be helpful when hybrid systems are required, said Howell. Software with modifiable templates allows you to quickly create GHS labels for your specific product, in the quantities you need, at the time you need them.
According to Heberling, relying on the free software along with the appropriate labels enabled his metal supply service center to become GHS compliant rapidly.
Once we had the labels, we complied with GHS requirements within a couple of hours, said Heberling. I printed what we needed on a desktop printer, and we affixed the labels to painted secondary containers with spray nozzles at the production lines.
GHS and HMIS labels such as Averys are available in a full range of sizes to fit drums, totes, pails, cans, jugs and even small bottles. They can be applied to a variety of surfaces including metal, plastic, glass, ceramic, polycarbonate, painted surfaces and more. Similar to the companys office labels, the GHS and HMIS labels offer easy-peel, smudge-free and jam-free capability.
What initially looked like a big project actually turned out to be quite simple, said Heberling. Since then, the GHS-compliant labels have not only passed a corporate audit, but also improved the safety of the production lines and employees.
While GHS label compliance was mandatory, so was passing all safety audits, emphasized Heberling. The real bottom line, however, is that becoming GHS label compliant has improved our safety at the production lines. Now we are clearly displaying chemical data, to prevent mistakes of misidentification, along with other necessary information.
Howell believes that universal GHS label compliance will improve safety by minimizing the risk of chemical misidentification and mishandling along the entire supply chain – from manufacturer to end user, both domestically and internationally.
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, he reminded. So the entire supply chain will want to work with a GHS label provider like Avery and perhaps a consultant that will keep them up to date with these changes.
Del Williams is a technical writer based in Torrance, California. For more information, visit