The revised Hazard Communication (HazCom) Standard promulgated by the U.S. Occupational Health and Safety Administration (OSHA) implements changes to promote worker safety through the adoption of three primary tenets of the United Nations-sanctioned Globally Harmonized System of Classification and Labeling of Chemicals, otherwise referred to as GHS.

This article outlines key compliance requirements pertaining to OSHA’s GHS rule and provides a 3-part plan that employers can use to meet those requirements.

Overview

OSHA used GHS to transform its Hazard Communication Standard, which was promulgated in 1983, from a standard focused on “Worker Right to Know” to a standard focused on “Worker Right to Understand.”

Key provisions of the U.S. GHS requirements include:

• A new labeling system must be fully implemented by chemical manufacturers by June 1, 2015.
• Pictograms and statements must be included on container labels.
• A standardized format for Safety Data Sheets (SDS), formerly known as Material Safety Data Sheets, must be used to present essential emergency information about a product or chemical.
• Employers must provide initial training on the labeling and SDS requirements.

The intention of this significant modification is to provide consistency with international hazard communication; the United Nations formally adopted the GHS back in 2002. The changes also allow for faster recognition of each hazard associated with a chemical, which is vital in the event of an emergency. OSHA’s revised standard is based on many years of study and research, as well as the deliberations of a U.S. interagency committee including the Department of Transportation, Consumer Product Safety Commission, and Environmental Protection Agency. It is believed that these changes will significantly reduce the number and degree of injuries related to exposure to hazardous chemicals, saving lives and minimizing risk and liability for businesses.

3-Part GHS Compliance

To meet the requirements of GHS, employers should

1. Update facility plans and programs.
2. Select compliant labels for secondary containers.
3. Provide employee training.

1. Update Plans and Programs

Written programs must be revised to describe the new criteria for labeling, SDSs, and employee training. Employers will need to create a chemical inventory that includes new product identifiers referenced on the SDSs. So, as employers receive chemicals with GHS-compliant labels and accompanying SDSs, we recommend using the original inventory to cross reference the new information. In addition to revising the written Hazard Communication program, ensure the consistency of this program with other plans, including emergency response plans, action plans, and chemical hygiene plans.

GHS Safety Data Sheets

SDSs must contain the following 16 sections:

1. Product/manufacturer information
2. Hazard(s) identification
3. Composition/information on ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information (date of last preparation or last revision)

2. Use GHS Labels for Secondary Containers

Many companies use NFPA 704 or HMIS labeling formats for secondary containers of hazardous materials used within their facilities or placed in chemical storage cabinets or rooms. While this is allowed under the standard, we recommend selecting GHS-compliant labels so as to minimize the confusion between the language and ratings on the new labels and SDSs.

The final HazCom rule requires the use of two signal words for labels: “danger” and “warning.” Danger is used for the more severe hazards; warning denotes less of a hazard.

Employers will need to decide how they want to format new labels and then develop a plan and schedule for label replacement within each of the areas. We recommend that employers plan in advance and arrange for this to take place immediately, if it hasn’t already occurred. Enlist the assistance of those employees directly affected by these changes.

3. Provide Employee Training

HazCom employee training programs must cover all details of the hazard communication program. This includes an explanation of the labels received on shipped containers, the workplace labeling system, and the new SDS format. Training must address the physical, health, simple asphyxiant, combustible dust, and pyrophoric gas hazards as well as hazards not otherwise classified. To prepare for this training, trainers must become familiar with the changes and understand the new hazard classification system that chemical manufacturers and distributors must now use to classify the hazards of their products.

Appendices A and B of 20 CFR 1910.1200 provide the specific procedures to be followed. Unless an employer is a chemical manufacturer, this training should have been provided by OSHA’s December 1, 2013 deadline. If it has not taken place, make appropriate arrangements to schedule and deliver documented training.

Because chemical manufacturers have until 2015 to completely convert their labels and SDSs to conform to the new standard, employees may find it confusing during the transition period. Training programs should be clear about the inconsistencies in labeling and SDSs that employees may see during the transition from the old to new system.

About the Author

Sandra Perry is the Director of Environmental Healthy and Safety Services at Triumvirate Environmental. Triumvirate provides innovative hazardous waste management, compliance consulting services, and field services to higher education, life science, healthcare, and industrial clients across the United States. Its technical services team offers specialized services that include program and plan development, reporting, regulatory training (OSHA, RCRA, DOT, IATA), onsite EH&S support, and multimedia compliance audits. Triumvirate has the ability to work with employers to meet each deadline associated with OSHA’s revised Hazard Communication Standard as well as to train employees about how this regulatory update affects operational roles.

Photograph: Harbour by Phillip Collier, Sydney, NSW, Australia.

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