Recent changes were made to the OSHA Hazard Communication Standard (HCS) in order to align more cohesively with the United Nations’ Globally Harmonized System of Classification Labeling of Chemicals (GHS).
The changes included new labeling requirements and a standardized format for Safety Data Sheets (SDSs). The modified standard provides set criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication details for labeling and safety data sheets.
The changes made cover over 43 million employees in more than five million workplaces across the country. According to OSHA, the benefits of these new requirements include reducing trade barriers by harmonizing with systems around the world, preventing over 500 workplace injuries/illnesses and 43 deaths annually, while saving American businesses approximately 475 million dollars.
In addition, workers will be provided better access to information on safety data sheets. There will also be better quality and consistency of hazard information implemented in the workplace. Finally, an increase in worker comprehension of hazards and safety training will lead to safer handling of chemicals.
The purpose of the new standards is to help employers provide a safer workplace for employees. The new standards are in sync with global standards and no longer permit chemical manufacturers and importers to convey hazard information in whatever format they choose. By implementing these standards, employers will reduce the number of injuries caused in the workplace, reduce preventable deaths, and save millions of dollars.
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Major Changes to the HCS
In order to ensure chemical safety in the workplace, information about the hazards of chemicals must be available and understandable to workers. The standard requires the development and dissemination of such information.
Hazard Classification: includes new specific criteria to address health and physical hazards as well as classification of chemical mixtures.
Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
Safety Data Sheets: 16 specific sections, ensuring consistency in presentation of important protection information.
Information and training: workers must be trained by December 1, 2013, on new label elements and safety data sheet format.
What Needs to Be Completed and When
The standards 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 the hazard information to their customers. All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train them to handle the chemicals appropriately.
The chart below details all of the requirements per employer and their effective completion dates.
Effective Completion Date
Dec. 1, 2013
Train employees on the new label elements and SDS format.
June 1, 2015*
December 1, 2015
Comply with all modified provisions of this final rule, except:
Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.
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.
Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both.
All chemical manufacturers, importers, distributors and employe
* This date coincides with the European Union implementation date for classification of mixtures
Information and training are a critical part of the hazard communication program. A well- conducted training program will ensure comprehension and understanding.
Important Facts and Requirements
- OSHA considers office products (such as pens, pencils, adhesive tape, etc.) as articles or consumer products and an exemption under the rule. Therefore, office workers who are only exposed to hazardous chemicals in isolated instances are not covered by the rule.
- Employers that do not produce or import chemicals should focus on establishing a workplace program and communicating information to their workers.
- Employees should be trained when they are assigned to work with a hazardous chemical.
- Employers must ensure that training makes employees aware of which hazard category (i.e., corrosive, irritant, etc.) the solvent falls within.
- Training must be in the language workers receive job instructions.
- Training should include an opportunity for employees to ask questions to ensure that they understand the information presented to them.
- Additional training is to be conducted whenever a new physical or health hazard is introduced into the work area, not a new chemical.
Preparing and Implementing a Hazard Communication Program
A written Hazard Communication Program is required and should describe how requirements are going to be met in your facility. When implementing your program consider the following items:
Designation of a person responsible for training. Hazard training and communication should be a continued initiative. It is important for the success of your program that someone is assigned responsibility for both the initial and ongoing activities that must be implemented in order to comply with the standard.
Format of the program used (classroom instruction, audiovisuals, etc). There should be enough information provided about the employer’s hazard training program to assess whether or not a good faith effort was made to train employees. The most significant aspects of training are to ensure that employees are aware that they are exposed to hazardous chemicals, that they know how to read and use labels and safety data sheets.
Elements of the Training Program
The rule does not require employers to maintain records of employee training, although, it may be helpful when monitoring your program. An employer is able to provide employees information and conduct training in whatever form they feel appropriate, however, there should always be some training on site.
Regardless of the method used, the employer is ultimately responsible for ensuring that employees are properly trained. If the compliance officer determines the training is deficient, the employer will be cited for the deficiency.
Employers must have a procedure in place to train employees when introducing new hazardous chemicals and when new employees are assigned to their work.
In addition to these items, consider the following questions:
• Is there a hazardous chemicals list in each work area or at a central location?
• What methods are being used to inform employees of the hazards of non-routine tasks?
• Are employees informed of hazards associated with chemicals contained in unlabeled pipes in their work areas?
• On worksites with multi-employers, was information provided to other employers about labeling systems and chemical exposure hazards?
• Is there a written program available to all employees?
Checklist for Compliance
1. Obtained a copy of the rule.
2. Read and understood the requirements.
3. Assigned responsibility for tasks.
4. Prepared an inventory of chemicals.
5. Containers are labeled.
6. MSDS for each chemical.
7. Prepared written program.
8. MSDSs available to workers.
9. Conducted training of workers.
10. Established procedures to maintain current program.
11. Established procedures to evaluate the effectiveness of program.
More specific and detailed information on the hazard communication standard can be found at www.osha.gov/dsg/hazcom/index.html.
Laurie Zabel is Director of Coding and Compliance at MedSafe.