**GHS Compliance** June 1, 2016
**2016 RTK Survey Update Reporting Year** Due to OSES by June 15, 2017
The Right To Know Program is managed by the Occupational Safety Specialist, Brian Deitch, he can be reached at firstname.lastname@example.org or extension 2881.
OSES has developed a GHS Compliance Log for those areas who wish to keep products that are no longer Globally Harmonized System (GHS) compliant and meet all the specific criteria. Please contact the Environmental Programs Specialist, Amanda Radosti via email at email@example.com for more information.
The Mandatory Right to Know (RTK) Survey is submitted annually to the NJ Department of Health through the Office Occupational Safety and Environmental Services for the entire campus. The Mandatory RTK Survey is the required means of communicating which chemical containing products with hazards are being stored and/or used on campus for the purposes of reporting to emergency responders, tracking of chemicals and occupational safety. Here at The College, the RTK and Hazard Communication Programs have been combined. As such, we report all chemical containing products within the RTK Survey. The RTK Survey will need to be a FULL list of items stored and used on campus each year.
Each year, an email will be sent from the Office of Occupational Safety and Environmental Services regarding the specific information due each year for the RTK Surveys. Each year the email will provide reminder instructions on how to complete that year’s Survey and refresher classes associated with the Survey that is due in June of each year.
Areas completing the Survey should take this inventory as an opportunity to confirm additional RTK, Hazard Communication, Chemical Hygiene, and Globally Harmonized System requirements are being met. Additional items that should be confirmed include:
•Every shipped container has the manufacturer label. Whenever possible, additional containers created by the user are labeled with the manufacturer provided label, otherwise the product identity, manufacturer’s name and address, hazard warning, target organs, chemical name and the top five ingredients are required to be on the container.
•Every container and/or secondary container is labeled in English.
•Some containers that do not have to be labeled are ones in which the chemical transferred is intended for the immediate use (by the end of the shift) of the employee who performed the transfer or containers such as test tubes, beakers, flasks, and similar which are used and reused in process for different substances.
•Containers which are two ounces or smaller may be labeled by chemical identity or using a code or number system. A code or number system can only be used if the code or number system will allow the employee or emergency responders ready access to the identity, names and CAS numbers or the trade secret registry numbers of the ingredients.
•There are special labeling considerations for office products, petroleum products, process containers, and some other materials. If you are unsure of labeling requirements, please contact OSES.
•Every chemical product has an available Material Safety Data Sheet/Safety Data Sheet near the location it is used as well as a copy sent to OSES. Hard copies are to be used unless a computer with access to the information is immediately available in the area in which the chemical work is being performed. For example, if the department office has a computer that has access to the required chemical information, but closes at 4:30pm and on weekends, this would not be appropriate for access to RTK information for labs using chemicals during off hours.
•Areas should confirm that the Material Safety Data Sheet/Safety Data Sheet is the most recent available from the manufacturer.
•Chemicals are being stored properly (compatibles stored together, secondary trays, etc.).
•Waste chemicals should be labeled and prepared for the next hazardous waste disposal.
•In anticipation of new requirements for the GHS that will go into effect in June 1, 2016 and as discussed in training it is recommended that you take the opportunity now to start looking for any changes in the hazard classification information coming from the manufacturers. While manufacturers aren’t required to complete this evaluation and update their product information yet, some have already begun or completed this process.
GHS Upcoming Compliance. As a reminder from training chemicals/products with hazardous by manufacturers that no longer exist or chemicals/products that are no longer are being manufactured, the following are required to be tracked through the department:
– A list identifying these chemicals/products as no longer manufactured, with the chemical/product location, identification name, and manufacturer name is available and accurate.
– The chemical’s/product’s most updated MSDS is available.
– Keep the original manufacturer label legible.
OSES has developed a spreadsheet for those areas who wish to keep products that are no longer GHS compliant. GHS Compliance Log
While the GHS compliance schedule is June 1, 2016, in June 2015, in association with our required annual RTK Survey OSES will be requesting to review and/or be made aware which areas are creating the list mentioned above for products they intend to keep that are not in compliance with GHS. Given the administrative burden of tracking these chemicals for each area and when possible it is best that these products are removed with the hazardous waste collection.
As a reminder, OSES is available to assist with the following:
•RTK Survey specific questions
•Provide a refresher session on the RTK Survey
•Assist and/or advise on Material Safety Data Sheets/Safety Data Sheets
•Review any new Material Safety Data Sheets/Safety Data Sheets from manufacturers that have reclassified a chemical product
•Any other RTK/Hazard Communication Program or GHS assistance as needed