On March 26, 2012, the Occupational Safety and Health Administration (OSHA) issued a final rule modifying its Hazard Communication Standard (HCS). The final rule aligns the HCS with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
OSHA’s intent in revising the standard is to improve the effectiveness of the HCS by ensuring that employees are informed of the chemical hazards to which they may be exposed and, consequently, to reduce the number of chemical-related occupational illnesses and injuries.
Q. What is the Globally Harmonized System?
The Globally Harmonized System (GHS) is an international approach to hazard communication, providing agreed criteria for classification of chemical hazards and a standardized approach to label elements and safety data sheets. The GHS was negotiated in a multi-year process by hazard communication experts from many different countries, international organizations and stakeholder groups. It is based on major existing systems around the world, including OSHA's Hazard Communication Standard and the chemical classification and labeling systems of other U.S. agencies.
Q. Why must training be conducted prior to the effective date?
OSHA is requiring that employees are trained on the new label elements (i.e., pictograms, hazard statements, precautionary statements and signal words) and SDS format by Dec. 1, 2013, while full compliance with the final rule will begin in 2015. OSHA believes that American workplaces will soon begin to receive labels and SDSs that are consistent with the GHS, since many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDSs. It is important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they will be familiar with them, understand how to use them and access the information effectively.
Q. What are the major changes to the Hazard Communication Standard?
The three major areas of change are in hazard classification, labels and safety data sheets.
- Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result.
- Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram and hazard statement for each hazard class and category. Precautionary statements must also be provided.
- Safety data sheets: SDSs will now have a specified 16-section format.
Q. When must label information be updated?
In the revised Hazard Communication Standard (HCS), OSHA is lifting the stay on enforcement regarding the provision to update labels when new information on hazards becomes available. Chemical manufacturers, importers, distributors or employers that become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information. If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.
If your company isn't up to OSHA's GHS and HCS regulations, it can cost on average up to sixteen hundred dollars worth of fines. Give one of our Clarke & Sampson, Inc. professionals a call today at 703.683.6601 so we can help prevent this happening to you!