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When asked whether they are fully prepared for GHS implementation, most manufacturers, importers, suppliers and users of hazardous chemicals will probably say “Yes”
In our experience, this is not the case, when answering yes, we have found that chemical manufacturers, importers, suppliers and users have often only considered the more obvious, high level aspects of GHS implementation, but as with many things, the devil is in detail, and they have invariably failed to consider all the challenges across their business as a whole.
Conversion to GHS in not straightforward, and there are significant changes in the new GHS system when compared to the existing approved criteria (NOHSC). This means there are many operational, risk management, compliance issues that will need to be addressed with the change to the new system- for example:
- Have you conducted GHS awareness training for your staff?
- Have you reclassified your chemicals in accordance with GHS requirements?
- Do you know how many of your chemicals have changed classification under GHS?
- Do your marketing strategies need to change to reflect classification changes?
- Do your insurance policies need to be updated to reflect classification changes?
- Are your labels configured to new GHS requirements?
- Have your IT systems been updated to incorporated GHS changes?
- Have you updated your risk assessments?
- Have you contacted your chemical suppliers about GHS and are they ready to change?
Managers and supervisors must understand the changes that are occurring to ensure chemicals supplied to their businesses are complaint with the GHS, and that they understand the potential impact on placarding requirements, dangerous goods manifests and segregation of chemicals resulting from changes in product classification.
“It is crucial that businesses develop a detailed 6- stage implementation plan to ensure that they are on track to have an orderly and timely transition to GHS. Workplace training sessions should start as soon as possible to educate staff on GHS system and their role in the transition.” said Shawn Samuel, CEO of Chemical Safety International.
Whilst there are many issues to be considered to ensure complete readiness for GHS implementation on 1 January 2017, help is available, and there is still time- if you start now!
So when faced with question “Are you GHS ready?” make sure you have spent the time to consider the full dimensions of GHS roll-out on your business, and have created a robust implementation plan that wil ensure you can confidently say, “Yes. We are ready”.
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- Is your business GHS ready?