If you are a safety professional or are responsible for safety within your organization, you are probably aware of the December 1st deadline that is quickly approaching. Companies must train all employees by this date on all of the changes related to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). GHS is an international system created by the United Nations that will significantly standardize how chemical hazards are communicated internationally, according to the health, environmental, and physical hazards related to any particular substance or mixture. GHS will introduce certain changes, such as the required use of health and environmental warning pictograms, that will be integrated into a country’s existing classification system (such as the HazCom system here in the U.S.). These changes will primarily impact the content of labels and safety data sheets (SDS).
While GHS will provide a much needed increase in consistency across countries in how chemical hazards are communicated, at the end of the day it will only impact classification and communication related to substances and materials. It is still up to the employer to ensure that hazards related to these substances are managed effectively. This means organizations across the globe will still have a high degree of control over how they manage exposures to hazardous substances during the manufacturing, transportation, and handling processes. Don’t get me wrong - labels that are more visual, consistent and convey more detail on associated risks are a great enhancement. But they will only be as effective as the safety management system that surrounds them, and the people that see (or don’t see) them.
There are three key points related to people that should be considered as your organization prepares for this important new safety initiative:
1. Labels Must be Noticed in Order to be Effective. The new labeling requirements related to GHS add a visual component through the use of universal pictograms that convey hazards in a simple manner. This should increase the likelihood of an employee noticing, seeing and reading the label. But it certainly does not guarantee it. Individuals actually differ greatly in their general awareness, and in how much detail they see in the environment. If I show a photograph or a simple picture to 50 people and then ask them questions about the image, research shows I will get a fairly broad spectrum of correct responses. That is because perceptual ability and memory recall, which help make up our unique SafetyDNATM, are individual abilities that are widely distributed across the general population. Therefore, we need to ensure that we account for these personal factors within our workforce, rather than assuming every employee will perceive labeling in the same manner. By measuring employee awareness levels and tailoring their training and coaching around this, we can further improve the success of an effective labeling system.
2. Reading About a Risk is Not the Same as Perceiving a Risk. When I went to college in Burlington, Vermont, I was surrounded by a lot of really, really good skiers. For many, it soon became quick that their main priority in choosing a university clearly was more about the quality of the slopes nearby than on academics (as evidenced by their class attendance). In fact, a couple of the guys in my dorm room came very close to making the US Olympic ski team. What stood out to me the most was that the very first day they hit the slopes, some of these elite skiers immediately headed for the black diamond trails, which are the most difficult (and dangerous, if you are not a skilled skier) and it took barely an hour before they were already bored with that and started to ignore the “No Skiing Allowed” and “Off Limits” signs to go off the trails. They were much more at home whizzing past trees, jumping off of 20 foot cliffs, and barely avoiding massive rock formations that could probably paralyze or kill them in an instant if they made a mistake. While several of the skiers at the school were just as skilled and accomplished, many did not feel the need to go off the trails. They were happy to heed the signs that were posted and stay on the marked trails. So it was not just a matter of skill and experience; it was also about what constituted “fun” for some of them, and how comfortable they were with risk. Needless to say, it made for some really awesome stories when they would get back to the dorms, and it was a great example of how we all see risk and danger in different ways.
My point here, simply put, is that just because I read a label that says something is dangerous, and I see a picture showing that I might get burned by it, it does not mean that I will feel in greater danger of being burned. And even if I do perceive increased risk of being burned, I may still feel that the risk does not really apply to me personally. Like anyone else, I will read and perceive the meaning of that label through the filters of my personal SafetyDNA, as well as the information I personally took away from trainings and previous experiences. Ultimately, my individual level of caution will largely dictate if, and how much, I modify my behavior once I see the label.
3. GHS Will Not Train & Implement Itself. Ultimately, employers themselves will be responsible for delivering effective training to their people on the key aspects of GHS. While several resources and aids are available to assist employers with training, and many outside contractors can assist with this process, successful roll-out of GHS will still require careful planning, effective communication, and consistent follow-up on the part of the employer. As with any training initiative, it will be important to consider unique aspects of the workforce, such as language/English proficiency, job experience, and learning styles. Knowledge of employees’ individual SafetyDNA (e.g., awareness, caution) will also impact the effectiveness of training efforts on the new system requirements. And last but not least, leadership will play a key role in providing support and ensuring that questions, concerns, and related process changes are handled in a timely and effective manner. This is where great safety leadership skills will come into play, and organizations with better safety leaders will see more consistent success because these individuals have the right skill sets and leadership competencies that are needed to drive important safety initiatives such as this. By addressing all of these factors related to training and implementation, your organization can help ensure that the transition to GHS will be successful and sustainable over time.
Our Whitepaper below discusses how your organization can build a safer, more productive workforce. Inside you’ll find 7 useful topics:
- The myth of the average worker
- Knowing who you are and what’s important in your organization
- Developing the right profile
- Screening out high risk candidates early on
- Why front-line leadership is crucial
- The importance of measuring your results