By Pete Rice, CIH, CSP, REHS
VP of EHS Programs
ClickSafety

We have all been hearing about OSHA’s new revised Hazard Communication Standard (HCS) aligning with the United Nations’ Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. The first of these revisions dealing with employee training has a Dec. 1, 2013 deadline, less than 60 days away! What does that mean for you? There are some major changes coming, but what needs to be done by the deadline? How do you stay informed and in compliance?

Quite simply, the Dec. 1 date is a training deadline to ensure that employees who may be exposed to workplace hazardous chemicals recognize and understand the new system of "labels" and "Safety Data Sheets (SDS’s)" being phased in over the next 2 ½ years. It is also a reminder to employers of their obligation under the provisions of OSHA’s HCS, that they are responsible for informing employees of the hazards and the identities of workplace chemicals to which they are exposed.

With an estimated 650,000 existing chemical products, and hundreds of new ones being introduced annually, these new HCS revisions incorporating GHS are pretty important, impacting more than 32 million workers working with, and potentially exposed to, one or more chemical hazards. Also, OSHA citations for HazCom are consistently in the top three of OSHA standards cited.

Actually over the next 2 ½ years there will be several revisions to HCS and several compliance dates. Major changes to the Hazard Communication Standard include changes to the classification of hazards, new "label elements" and a new "standardized format to Safety Data Sheets (SDS’s)", formerly known as Material Safety Data Sheets (MSDS’s). In summary of these changes:

• Hazard classification: Provides chemical manufacturers, suppliers and distributors specific criteria for classification of health and physical hazards, as well as classification of mixtures.
• 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 (SDS’s): Will now have a specified 16-section format.

What is required by Dec. 1 is that employers must have trained their workers on the new "label" elements and new "SDS format." OSHA is concerned that employees are already beginning to see the new labels and SDS’s on the chemicals in their workplace and need the training to better understand and be informed of their meaning and significance.

OSHA believes that this revision standard will:

• Improve the quality and consistency of hazard information, making it safer for workers to do their jobs and easier for employers to stay competitive.
• Provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and SDS’s.
• Help reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store, and use hazardous chemicals.

In order to be in compliance, the minimum required topics for the training that must be completed by Dec. 1, 2013 include:

Tip: 

Chemical exposure may cause or contribute to many serious health effects such as heart ailments, central nervous system, kidney and lung damage, sterility, cancer, burns, and rashes. Some chemicals may also be safety hazards and have the potential to cause fires and explosions and other serious accidents.

• Standardized 16-section format, including the type of information found in the various sections. For example, the employee should be instructed that with the new format, Section 8 (Exposure Controls/Personal Protection) will always contain information about exposure limits, engineering controls and ways to protect yourself, including personal protective equipment.
• How the information on the label is related to the SDS. For example, explain that the precautionary statements would be the same on the label and on the SDS.

Employers are encouraged to stay informed and in compliance with the revisions to OSHA’s HCS. In the next 60 days, that means preparing your employees to recognize the new labels and SDS’s they will be seeing on the jobsite. Periodically refer to OSHA’s Safety & Health Topics Page: Hazard Communication at https://www.osha.gov/dsg/hazcom/index2.html.

During the training, an employer might ... 

✓ Explain how information on the label can be used to promote proper storage of hazardous chemicals.

✓ Explain how the information on the label might be used to quickly locate information on first aid when needed by employees or emergency personnel.

✓ Explain that where a chemical has multiple hazards, different pictograms are used to identify the various hazards.

✓ Explain that when there are similar precautionary statements, the one providing the most protective information is most important.