By Jill Obrochta & Heather Whitt/ Dental Enhancements
OSHA. This monotonous, tedious subject may not always be on the forefront of your mind but from now through June 1,2015, OSHA / GHS is something to pay close attention to. Global Harmonization System (GHS) is OSHA’s new big brother and he’s out to grab the world’s attention. Dental offices best be prepared as this International OSHA module has a second deadline that you must be mindful of and compliant within your dental facility.
Global Harmonization System (GHS), is a rather symphonic name for what more simply should be referred to as “international chemical safety.” GHS is a result of the World Summit Meetings that took place more than a decade ago. World leaders realized a need to standardize workplace chemical handling and safety procedures to lessen the growing number of chemical workplace accidents and injuries throughout the world. Congruent standards were established and efforts were made worldwide to implement these new chemical handling safety regulations. The United Nations, Europe and Canada all have gracefully implemented the new GHS standards. The USA thoughtlessly lags behind with implementation, but now under the jurisdiction of OSHA, USA must make up strides to prove compliance with GHS in three areas: Proof-of-Employee Training, Updated Paperwork and Facility Compliance.
While dental offices may not be primary users of dangerous or flammable chemicals, these rules apply to all USA businesses and dental offices are getting their share of fines. The first compliance deadline date for GHS—Hazard Communication System (HCS) was December 1, 2013. By that time employers were required to have all employees (full and part timers; clinical and non-clinical workers alike) trained on the new International GHS pictogram labeling system and the transformation of USA—MSDS to International SDS format. Not sounding familiar to you? Then read on, there is compliance information that needs to be indisputably in place in your dental office. And you are considered to be delinquent and non-compliant if you have not completed the GHS requirements within your dental office. Don’t mistakenly think that your Annual OSHA Employee Training will suffice to get you fully attuned to the new International GHS requirements. GHS is an entity all of its own. While the particular twists and turns of GHS can be mind-numbing and overwhelming, there is a way to get your team compliant in less than two hours, affordably, while satisfying all three requirements: Proof-of-Employee Training, Updated Paperwork & Facility Compliance. Read on.
Phase I– GHS Employer Mandates were required early in the USA transition process (due December 1, 2013) since workers would begin to see new symbols called pictograms (international chemical hazard rating symbols) and new standardized SDS (international safety data sheets) within their workplace. Employee training in GHS was mandated to ensure employees had the information they needed to better protect themselves from chemical hazards in the workplace during the transition period. Pictogram diagrams should have already been posted within your office and you must have written protocols in place explaining how you approach the conversion of USA MSDS to International SDS. Cloud, digital or paper storage of the new International SDS are allowed with two of the three aforementioned being mandatory. You must have a working copy and a back-up copy of the new SDS and one version must be accessible to employees 24/7.
Phase II– GHS Manufacturer Mandates puts obligation on USA manufacturers & importers to update and make available: Pictograms on all professional product and chemical labels and also to publish new SDS. So how does Phase II GHS effect the dental office? Accountability, preparedness and certified comprehension are what OSHA inspectors are looking for and they will be stepping up their game! Many states will initiate rotating mandatory cyclical OSHA inspections and others are applying additional State mandates plus fines that help support International GHS implementation. The bottom line holds the dental practice owner and all employees accountable in areas of: Proof-of-training in GHS, updated / upgraded paperwork required for GHS (new OSHA manual written to GHS Standard and paper copies of SDS) and functioning office protocols (pictogram diagram posted, cloud, digital SDS libraries functioning).
Phase III—GHS Manufacturer & Employer Mandates This final phase will occur in June of 2016. It will hold both manufacturers and employers accountable in an even stronger degree. Non-compliance will bring bigger, bolder fines and OSHA Inspectors are expected to bear down with exuberance. Follow-up to the Earth Summit Meetings and accountability from all countries involved will be the next phase. USA will have to produce compliance statistics so logically, more citations and fines will be the fore runner to our accountability.
This story is not so grim. It’s a process that will be monitored and enforced more rigorously as each phase occurs. If your dental office has not yet become familiar with or certified in GHS, why not take the easy-fast track toward success. Choose GHS Solutions that offer all requirements: Training/Certification, Required Paperwork & Facility Protocols. Having access to a GHS Expert for guidance and ongoing support will ensure your success if the GHS program takes on additional nuances as time goes on. The Dental Advisor rated one GHS kit their favorite in 2014: The OSHA made EASY®–GHS COMPLETE COMPLIANCE PKG provides all three GHS required components, plus guided help from an OSHA/GHS expert to implement the protocols within your office. This package differs from others in that it is in ready-to-use format, not a kit that will take additional hours to design. The 24/7 access to GHS support makes it even more valuable when implementing. The American Dental Association and dental suppliers may offer GHS solutions as well.
If you still need to implement GHS Standards within your office, make sure to execute a comprehensive program. Keep in mind that OSHA Inspectors will get more demanding in this area of International Hazard Communication Compliance. Now that you are educated, be dutiful, get GHS in place within your dental office and get back to what you do best. Dentistry!
Dental Enhancements offers a free GHS Survival Guide & Personalized Phone Assessment. Click here to receive your FREE GHS OSHA & HIPAA Inspection Survival Guides. These tools will demystify OSHA/GHS & HIPAA Compliance. They will inform and enlighten you on how to create comprehensive programs for your dental office. Ones that will impress the most meticulous OSHA or HIPAA Inspectors.
For a complimentary GHS consultation, call: 941-587-2864