The new Hazard Communication Standard: What you need to know to be compliant
Both producers and users of chemicals will be affected by the upcoming changes to OSHA’s Hazard Communication Standard (HCS). The existing HCS provides guidance for defining chemical hazards but is not consistent with global standards. While the intent and scope of HCS will remain the same, OSHA has decided to align HCS with the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals to introduce global consistency.
The new standard covers over 43 million workers who produce or handle hazardous chemicals in more than five million workplaces across the country. The modification is expected to prevent more than 500 workplace injuries and illnesses and 43 fatalities. Once fully implemented, the standard will also:
- Improve the quality and consistency of hazard information in the workplace, making it safer for workers to do their jobs and easier for employers to stay competitive.
- Enhance worker comprehension of hazards, especially for low and limited-literacy workers, reduce confusion in the workplace, facilitate safety training, and result in safer handling and use of chemicals.
- Provide workers with quicker and more efficient access to information on the SDSs.
- Result in cost savings to American businesses of more than $500 million in productivity improvements, fewer SDS and label updates, and simpler new hazard communication training.
- Reduce trade barriers by harmonizing with systems around the world.
There are four major changes to the existing standard: hazard classification, labels, data sheets, and training.
Chemical manufacturers are required to determine the hazard and classification of the chemicals they produce or import, and will be required to follow the new, specific criteria outlined by GHS. Businesses that distribute or use the chemicals will not need to do their own testing to determine the classification of the chemicals unless they are modifying the chemicals received from the manufacturer.
After appropriate classification of the chemicals, chemical manufacturers will be required to create hazard labels according to GHS guidelines that include: the product identifier, supplier identification, hazard pictogram(s), signal word, hazard statement(s), and precautionary statement(s).
OSHA has not changed the general requirements related to workplace labeling; employers have the option to create their own workplace labels and/or continue to use rating systems such as the National Fire Protection Association (NFPA) diamonds or follow the Hazardous Materials Identification System requirements for workplace labels as long as the employees have immediate access to the specific hazard information.
In addition to creating the GHS hazard label, the chemical manufacturer is also responsible for creating a Safety Data Sheet (SDS). The major difference between SDS and the existing MSDS is the required 16-section format, which is still very similar to the current voluntary ANSI standard found on many MSDS today.
As a result of these changes, training will be extremely important for anyone handling chemicals, including manufacturers, importers, distributors, and end users. By December 1, 2013, employers must train all of their employees to be able to recognize and understand the GHS guidelines related to hazard classification, labels, and SDS format.
The OSHA rules recognize that full implementation of GHS by chemical manufacturers, importers, distributors, and employers must be complete by June 1, 2015. There are two exceptions: Distributors have an additional six months to ship products labeled by manufacturers under the old HCS, and employers have until June 1, 2016 to update their workplace labeling systems.
There will be costs associated with GHS compliance, with most of those costs being incurred by the chemical manufacturers. Potential costs include assigning personnel and resources to create the new labels and SDS, as well as the cost to train employees. OSHA strongly believes the benefits of implementing GHS will significantly outweigh the costs, with the ultimate goal of reducing workplace injuries and fatalities.
HCS has historically been on OSHA’s top-cited list, and OSHA will be increasing inspection activity related to GHS over the next several years. By following the implementation dates set by OSHA, businesses can avoid costly citations. There are a number of resources available on OSHA’s website; if you would like additional information, visit Grainger.com and search GHS.
Kelli Baker has the OSHA-30 certification and has facilitated various webinars and seminars related to GHS. Wes Maertz is an Authorized Outreach OSHA trainer and is a Certified Safety Professional.