Hazard Communication Standard: New Chemical Provisions

How many of you are old enough to remember when OSHA introduced the MSDS and Right to Know programs into the American workplace? This was a disruptive time and quite sizable cost to most businesses to adopt this regulation into their workplace and employee introduction of the program details.

Here we go again...

In June 2012, the United States adopted the same standards as 25 other industrial countries for information regarding the identification of hazardous materials in the workplace. It is a logical and comprehensive approach to:

• Defining health, physical and environmental hazards of chemicals;
• Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria; and
• Communicating hazard information, as well as protective measures, on labels and Safety Data Sheets (SDS).

OSHA is the authority agency for implementation, and requires changes that are incorporated into the Hazard Communication Standard (HCS) and adopted new classification of hazardous materials to fall in line with a universal identification system. These changes are now under way as the HCS aligns with the Globally Harmonized System (GHS) of classification and labeling of chemicals utilized around the world. These revisions are significant and affect all employers who manufacture, distribute, store and use chemicals.

To help companies comply with the revised standard, OSHA is phasing in the specific requirements during the next few years.

Phase 1 is Orientation Training, which must be completed by Dec. 1, 2013.

These regulations affect:

• Labels—new format for product and transportation;
• Symbols—pictograms are new and different than what we were taught to recognize; and
• Employee education—general orientation and familiarization.

It is estimated that more than five million workplaces in the United States will be impacted by the revised HCS. These are all those workplaces where employees—a total of approximately 43 million of them—could be exposed to hazardous chemicals. OSHA anticipates that these changes will make the workplace much safer, because the universal classification and labeling system will make it easier for everyone to understand the proper handling procedures and uses for all chemicals. As a result, trade barriers should be reduced and American businesses that deal with hazardous chemicals should see increased productivity at a higher cost savings.

Key Elements of the New Standard

Key provisions of the revised Hazard Communication Standard include:

Hazard classification: There will be a new system and set criteria for classifying the hazardous properties of chemicals. This classification system offers very specific instructions as to the classification of any and all health and physical hazards in addition to mixtures' classifications.

Labels: Under the new labeling system all chemical importers and manufacturers will be expected to utilize labels that include a signal word, pictogram and hazard statement from the new harmonized system.

Safety Data Sheets: Detailed chemical safety information will be required and must follow a uniform, 16-section format.

Information and Training: Employers are required to train workers by Dec. 1, 2013, on the new GHS label elements and safety data sheets format to facilitate recognition and understanding. This is required to aid in the recognition and understanding of these important changes.

Pharmaceuticals, food additives, cosmetics and pesticide residues in food will not be covered by the GHS at the point of consumption, but will be covered where workers may be exposed (workplaces), and in transport. Also, the medical use of human or veterinary pharmaceuticals is generally addressed in package inserts and is not part of existing hazard communication systems. Similarly, foods are generally not labeled under existing hazard communication systems. The exact requirements for labels and Safety Data Sheets will continue to be defined in national regulations.

The new Safety Data Sheet provides information in an entirely new format and resource to obtain advice on safety precautions. The SDS information enables the employer to develop an active program of worker protection measures, including training, which is specific to the individual workplace, and to consider any measures that may be necessary to protect the environment.

Information in a SDS also provides a source of information for other target audiences such as those involved with the transport of dangerous goods, emergency responders, poison centers, and those involved with the professional use of pesticides and consumers.

Whether this is the first time you are hearing about this change, or if you have a transition program already under way, being able to call on knowledgeable experts can ensure you stay compliant throughout this transition period. PI

About the Author

Dale Rothenberger has more than 20 years of experience in business transformation and program process management. He is available for consultation and can be reached at d.rothenberger@zeemedrdg.com or by calling (610) 926-1401.