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By Del Williams
Maintenance and engineering managers who organize paints and coatings projects at their institutional and commercial facilities must now ask if their chemical labels are Globally Harmonized System (GHS) compliant — and if not, be prepared to document for OSHA their good faith efforts to become so, and include an expected timeline for reaching compliance.
The industry will also need to determine how to integrate such compliance with the American Coatings Association's (ACA) Hazardous Materials Identification System (HMIS).
GHS was established by the United Nations to create a unified system for identifying and communicating hazardous chemicals. 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 a June 2016 deadline for end users.
Paints and coatings formulators must re-classify any products containing hazardous chemicals based on a common chemical classification system defined by GHS. They must update their safety data sheets and use GHS-compliant labels to identify their hazardous chemicals.
Paints and coatings importers and distributors must ensure that any products with hazardous chemicals have GHS-compliant safety data sheets and GHS-compliant labels.
Employers with any paints or coatings containing hazardous chemicals in the workplace must ensure they have safety data sheets and labels for their exposed workers, and train them to handle the chemicals properly.
On each GHS label, six specific items of data are required:
product name or identifier
GHS pictogram symbols
Instead of the familiar black and white pictogram symbols previously used in safety labeling, environmental health and safety (EHS) managers must realize that GHS labels now require pictogram symbols that convey hazard information with a red diamond border.
For those currently using HMIS labels for in-plant containers, related written documentation, and training, the question is how to achieve GHS compliance and integrate it with HMIS, which has been a paint and coatings industry standard for decades. Though differences exist in the two systems, such as opposite numbering for the level of hazard, OSHA allows employers to use HMIS in the workplace as long as it is consistent with GHS (HCS 2012) and workers are properly trained for GHS.
Implementing GHS labeling can seem daunting, particularly to small- and medium-sized businesses. While large organizations can hire integrators to automate GHS software with a bank of printers tied into high-end ERP infrastructure, small and medium sized businesses do not require this approach.
Instead of investing in costly dedicated printer/label/software systems, small- to medium-sized companies are easing the transition to GHS label compliance. More are turning to flexible, lower cost options, such as industrial-grade labels from Avery, that allow printing durable GHS, HMIS, or hybrid labels on demand with existing laser printers and certain inkjet printers.
As such, Avery designed its UltraDuty GHS Chemical Labels to meet the most rigorous GHS requirements. The durable synthetic 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, they are UV resistant with more than two years of outdoor UV life. They are also temperature resistant, can be applied as low as 10 degrees and used as high as 220 degrees in the field when printed from color laser printers or 300 degrees when printed from inkjet drum label printers.
“Staying GHS compliant will not only help paint and coating industry organizations avoid OSHA fines, sanctions, or auditing, but also will help them open new global markets since GHS is a global standard,” says Glen Markham, Vice President of Business Development at RightAnswer.com, Inc., a chemical compliance and information specialist.
Markham notes that remaining GHS label compliant depends on the durability of the appropriate label substrate, getting the label content right, and effective document management.
“Companies in the paint and coatings industry that have long used HMIS labels will now also want the ability to print GHS labels, HMIS labels, or some alternative that will accommodate the requirements of both systems,” says Markham. “Such flexibility will help ease the industry’s transition to GHS labeling and minimize any operational disruption.”
To help small and medium sized organizations print GHS and HMIS labels from their existing printers on demand, some companies provide label-printing software along with their labels.
Avery, for instance, provides such GHS and HMIS-compliant label software at no cost. The Design & Print GHS Wizard makes it easy for employees to create and print their own GHS and HMIS labels from pre-designed templates. They can also create them step-by-step on demand at their desk, and even create GHS and HMIS hybrid labels capable of satisfying both systems. Most employees will find the process intuitive, since it resembles creating an office document from pre-designed templates.
The free software includes all the pictograms and GHS compliant statements needed for GHS labeling; easy insertion of company logo or other images; customizable text; simple generation of 18 types of barcodes; and a sequential numbering feature to add lot numbers or other variable data.
No download is required since the software operates from Avery’s website (www.avery.com/GHS1), and GHS and HMIS labels can be securely saved online or to a computer. Besides GHS compliant labels, the software is also capable of printing other safety labels such as NFPA, OSHA, ANSI, and DOT labels.
The GHS and HMIS 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 Avery’s office labels, the GHS and HMIS labels retain easy peel, smudge-free, and jam-free capability.
For labeling that requires the durability of extra lamination, the company also offers easy align self-laminating ID labels, which come with a clear laminate so no lamination machine or additional layer of tape is needed. The material is ultraviolet and water resistant, and resists scuffing, tearing and smudging, making them ideal for use in warehouses, storage areas and worksites.
To help companies stay compliant for GHS, HMIS, and other regulatory situations, including OSHA safety communication, Avery has partnered with RightAnswer. Through a portal in Avery’s website, RightAnswer offers comprehensive online access to more than 100 proprietary, government, and EHS data sources with over 11 million documents covering more than 400,000 chemical substances, all integrated and available through a single interface.
“For paint and coatings related companies that keep asking EHS managers to do more with less, Avery’s partnering with RightAnswer can help them stay not only GHS and HMIS label compliant, but also up to date on the chemical issues they’re concerned about,” says Markham. “It’s an online one-stop chemical compliance and information solution that’s offered at a discount through the Avery website portal.”
Del Williams is a technical writer based in Torrance, Calif.