Article Contributor: Betsy Sibila
During the past three years there have been gradual changes to OSHA’s Hazard Communication Standard (HCS) to align HCS with the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The changes in the standard effect hazard classification, labels and pictograms, safety data sheets (SDS) and employee training. The revised standard not only provides employees the “right to know” but also the “right to understand.” HazCom 1910.1200
The phase-in period for GHS requirements includes four key dates:
- December 1, 2013 — Train employees on the new label elements and SDS format
- June 1, 2015 — Chemical manufacturers and importers must provide GHS-compliant labels and SDS
- December 1, 2015 — Distributors shall no longer ship containers labeled by the chemical manufacturer, or importer unless they have GHS compliant labels
- June 1, 2016 — Employers must update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical, or health hazards
The current HCS requires:
- Chemical manufacturers, and importers to evaluate the hazards of the chemicals they produce or import, and prepare labels and safety data sheets to convey hazard information to customers
- All employers with hazardous chemicals in the workplace must provide proper labeling, SDSs, and employee training on safe chemical handling
- The revisions to the HCS requires chemical manufacturers and importers to include the following on container labels:
- Signal word
- Hazard statement
- Precautionary statement
- Chemical manufacturers must provide customers with a GHS-standardized 16-section SDS to replace the previous material safety data sheet (MSDS).
What do you need to do?
Effective June 1, 2016, OSHA expects employers, distributors, chemical manufacturers, and importers to be in compliance with HCS 2012 which incorporates the requirements of GHS. Here are steps to take to make sure you are in compliance:
- Update your written Hazard Communication Program
- Review your chemical inventory and make sure you have the most current SDS
- Compare new SDS to MSDS to identify any additional hazards
- Ensure all labels have the required hazard information
- Ensure employees are trained to understand the new labeling system, SDS, and associated hazards
KPA continues to update the online MSDS database as SDS become available. This will be an ongoing process as new, or revised SDS information is distributed. In the absence of an SDS, make sure to maintain the most current MSDS in your library.
For additional information about HCS and GHS compliance, please contact a KPA Risk Management Consultant, or email [email protected].