OSHA REVISES HAZARD COMMUNICATION
Introduction to the Hazard Communication Standard
The Hazard Communication Standard (HCS) was enacted in to provide information to workers regarding the potential hazards associated with chemicals used in the workplace. The information is provided through various materials including, but not limited to, Material Safety Data Sheets (MSDS), placards, labels, and training programs. Employers are responsible for ensuring proper hazard communication programs are in place that provide information regarding materials stored, used, and manufactured in the workplace.
What Are the Major Changes
The final HCS rule was promulgated to conform to the United Nation’s Globally Harmonized System of Classification and labeling of Chemicals (GHS). The revised criteria include changes to Hazard Classification, Label Requirements, Safety Data Sheets, and Information and Training.
The final HCS rule is designed to comply with the definitions set forth by GHS and unify the hazard classes across the board to alleviate confusion. Currently, a product may be classified as “Flammable” by one definition and
“Combustible” by another, this rule standardizes the definition to eliminate conflicting classifications. The new standard defines then further sub-divides into Divisions, Categories, or Types: Physical, Health, and Environmental Hazards. Examples of Physical Hazards include Explosives, Flammable substances, Oxidiers, Gases under pressure, Self-reacting substances, Pyrophoric substances, Self-heating substances, React violently with water, Organic peroxides, and Corrosive to metals. Examples of Health Hazards include Acute toxicity, Skin corrosion/irritation, Serious eye damage/eye irritation, Respiratory or skin sensitization, Germ cell mutagenicity, Carcinogenicity, Reproductive toxicology, Target organ systemic toxicity, and Aspiration toxicity.
Examples of Environmental Hazards are Hazardous to the aquatic environment, Acute or chronic aquatic toxicity, Bioaccumulation potential, and Rapid degradability.
Chemical manufacturers and importers must provide a label that includes:
- Signal word “Danger” or “Warning”
- Standard Hazard statements assigned to a hazard class and category
- Precautionary statement for each hazard class and category
- Product identifier and ingredient disclosure of hazardous products
- Supplier name, address, and telephone number
Employers are responsible for ensuring employees are properly trained on reading the new labels. Displays of the pictograms and associated meanings should be made readily available to all employees.
Safety Data Sheets
The Safety Data Sheets (SDS) will replace MSDSs in providing information regarding hazards of hazardous chemicals and mixtures. Like MSDS, the SDS will include information regarding the properties of the chemical including, but not limited to, physical, health, and environmental hazards, protective measures, and safety precautions. The SDS will be in a uniform 16-section format ensuring consistency from different manufacturers and products. The general outline is as follows:
- Sections 1 through 8: general information regarding chemical identification, hazards, composition, handling, and emergency control
- Sections 9 through 11: technical and scientific information regarding physical and chemical properties, stability and reactivity information, toxicological information, and exposure pathways
- Sections 12 through 15: included to be incompliance with GHS standards but are not enforced by OSHA gencies and include ecological hazards, disposal, transportation, and regulatory requirements
Section 16 is used for additional information such as preparation/revision date, changes that have been made to the SDS, and other useful information.
Information and Training
HCS training requirements include: Recognizing and interpreting SDS, Recognizing and interpreting new labels, Pictogram meanings, and New hazard classification
definitions. All employees must be trained who use or work in close proximity to a hazardous chemical, loading or unloading areas, hazardous waste disposal areas, chemical storage areas, or other identified employees that have the potential of coming into contact with a hazardous chemical.
OSHA determined the final rule will:
- Reduce cost and increase productivity
- Prevent an estimated 43 fatalities and 521 chemical-related illnesses and injuries annually
- Expand international trade by reducing trade barriers for products covered by HCS
- Improve the quality and consistency of information
- Reduce the number of SDS and label updates Simplify the hazard communication training
- Provide employees with faster and more efficient access to information on the SDS and labels
- Provide information to low and limited-literacy workers
- Provide the information needed to result in safer handling and use of products covered by HCS
December 1, 2013 - Employers must have all employees trained on the new label elements and SDS format
June 1, 2015 - Chemical manufacturers, importers, distributors, and employers must be in compliance with all modified provisions of the final rule, except distributors may continue to ship products labeled by manufacturers under the old system until December 1, 2015
June 1, 2016 - Employers must have all alternative workplace labeling and hazard communication programs updated as necessary, and provide additional employee training for newly identified physical or health hazards.
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