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Revised OSHA Standards Ensure Chemical Safety in the Workplace

The Occupational Health and Safety Administration (OSHA) revised the Hazard Communication Standard (HCS) to align with the European Union’s (EU) Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The revised standard was published in March 2012, and, while there are some significant changes, the intent remains the same: to ensure chemical safety in the workplace. OSHA estimates the revised HCS covers 43 million employees in five million workplaces. The revision affects all companies who must comply with OSHA standards.

According to osha.gov, OHSA modified the Hazard Communication Standard (29 Code of Federal Regulations (CFR) 1910.1200 and Appendices A-E) to adopt the GHS to improve safety and health of workers through more effective communications on chemical hazards. The site explains the original standard is performance-oriented, allowing chemical manufacturers and importers to convey information on labels and material safety data sheets in whatever format they choose. A more standardized approach to classifying the hazards and conveying the information will be more effective, and provide further improvements in American workplaces. Adoption of the GHS in the U.S. and around the world will also help to improve information received from other countries—since the U.S. is both a major importer and exporter of chemicals, American workers often see labels and safety data sheets from other countries.

The major changes to the HCS are in hazard classification, labeling, and safety data sheets (SDS), formerly material safety data sheets (MSDS). The changes include:

  • Hazard classification: While similar to the previous hazard assessment requirement, the definition of hazard has been changed, and now there are specific criteria for classifying health and physical hazards. Mixtures must also be classified. The health and physical hazard criteria are specified in Appendices A and B, respectively. In addition to classifying the hazards, the hazards must be categorized by severity from 1-4, with 1 representing the most severe hazard. This is opposite to the conventions we have used in the U.S. previously, although OSHA has said that employers may continue to use the National Fire Protection Association and Hazardous Material Information System as long as those labels do not obscure or contradict OSHA-required information.
  • Labels: Chemical manufacturers and importers must 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. Appendix C contains the information that must appear on the label for health and physical hazards.
  • SDS: SDSs must be in a 16-section format similar to the American National Standards Institute standard for Hazardous Workplace Chemicals-Hazard Evaluation and Safety Data Sheets and Precautionary Labeling Preparation. Appendix D contains the specified sections and the information that must be included.

All of these changes will require retraining of employees, for which OSHA has provided a specific timetable, with final compliance required by June 2, 2016. (See the chart below for details.)

The final rule also made changes in other OSHA general industry, shipyards, and construction standards that are linked to hazard communication. Affected standards include, but are not limited to, the following:

  • Flammable liquids are defined somewhat differently under GHS, and definitions do not include combustible liquids. Standards that cover flammable liquids have been revised to reflect the new definitions and sign and label requirements.
  • Sign and label requirements in chemical-specific standards including, but not limited to, asbestos, lead, and hexavalent chromium have been revised to include signal words and standard hazard statements. Hazard communication requirements in these standards have also been revised to align with HCS.
  • Process safety management and hazardous waste operations standards definitions have been revised.

For a side-by-side comparison of the current HCS and the final revised HCS, please see OSHA’s hazard communication safety and health topics webpage. All of this information can seem overwhelming, but Terracon can provide help with any element of the standard, from helping to update the company HCS, or providing site-specific training, to preparing SDSs. Please contact us if we can help your organization adjust to the new regulations.

EFFECTIVE COMPLETION DATE REQUIREMENT(S)    WHO
December 1, 2013 Train employees on the new label elements and safety data sheet
(SDS) format.
   Employers
June 1, 2015 – December 1, 2015 Compliance with all modified provisions of this final rule, except:

The distributor shall not ship containers labeled by the chemical manufacturer or importer unless
it is a GHS label.

   Chemical manufacturers,
importers, distributors,
and employers
June 1, 2016 Update alternative workplace labeling
and haz­ard communication program as necessary, and provide additional
employee training for newly identified physical or health hazards.
   Employers

 


What is GHS

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.

GHS provides harmonized classification criteria for health, physical, and environmental hazards of chemicals. It also includes standardized label elements that are assigned to these hazard classes and categories, and provides the appropriate signal words, pictograms, and hazard and precautionary statements to convey the hazards to users.

source: osha.gov