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TABLE 1.
It’s amazing the attention a deadline gets. Last fall, there was quite a buzz around OSHA’s Dec. 1 GHS training deadline. In case you missed the buzz, GHS stands for Globally Harmonized System and will bring the United States into alignment with worker Hazard Communication standards adopted by the United Nations. GHS involves some changes in the way hazardous materials are classified, and a new format for labels and Safety Data Sheets (SDS), formerly known as Material Safety Data Sheets (MSDS) that is consistent throughout most of the world.
These changes are being phased in over the next two years with various deadlines for when all materials must carry the new labels and when your MSDS book has to be converted over to the new SDS format, see Table 1. The first deadline was last Dec. 1, and you should have trained your staff on the upcoming changes by that date. If you haven’t held that training, you should do so right away.
What I think was overlooked in all the hype over the GHS deadline was the importance of the overall Hazard Communication Standard and your obligation to regularly train your employees in how to recognize and handle hazardous materials. I talked to more than a few golf course superintendents who were very concerned about the GHS deadline but weren’t meeting the basic requirements of a Hazard Communication Plan.
OSHA’s Hazard Communication Standard, which is sometimes referred to as Haz Com or a “Worker Right to Know” law, was first introduced in 1983 and has five elements:
- Materials inventory
- Labeling
- MSDS/SDS book
- Training
- Written plan
Very few of the golf courses I work with have all five elements. Most courses keep a materials inventory and MSDS book, and the products in their chemical room are properly labeled. But to be compliant with the OSHA standard you must also train your employees and have a written plan. A written hazard communication plan is just a means of tying all of the elements together and stating how you are complying with the standard. There is a template available on the OSHA website but really all you need to do is list the name and title of the person responsible for maintaining the plan (your safety coordinator), how all hazardous materials will carry proper labels, where you keep the inventory and SDS book, how all written materials (labels, SDS, inventory and the written plan) are available to all employees, and how and when you conduct employee training. Keep a copy of the plan in your safety file (and make it available to all employees) and make sure you hold a Haz Com training meeting so that all employees are aware of the program and know how to recognize and deal with hazardous materials that they use in their job.
In addition to the template for a written Haz Com plan the OSHA website has many other resources that can help with your Hazard Communication training. Here are a few you might find helpful:
Hazard Communication Safety Data sheets
Hazard Communication Labels and Pictograms
Model plan for Blood Bourne Pathogen and Hazard Communication.
About the author
Mickey McCord is the founder of McCord Golf Services and Safety, providing safety training for superintendents and turf maintenance crews. Check him out at mccordgolf.com and on Twitter at @mccordgolf.
