OSHA approves new regulations associated with the Hazard
Communication Standard (HCS) and the mandatory adoption
of the Globally Harmonized System of Classification
and Labeling of Chemicals (GHS).
Last spring the U.S. Occupational Safety and Health Administration (OSHA) adopted updates to the Hazard Communication Standard (HAZCOM 2012), which included the adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). HAZCOM 2012 impacts industrial and institutional chemical manufacturers, distributors, and businesses like yours. GHS is an international approach to hazard communication, which provides a standardized approach to label elements and safety data sheets.
As the name implies, the GHS system is global in scope, with more than 40 countries using this labeling system for a number of years. So, even though the United States is coming onboard now, the GHS is not new and has proven to provide consistent product hazard identification and improved hazard communication to businesses and employees throughout the world. As of this writing, Canada is considering adoption of GHS.
You may wonder why OSHA has modified the Hazard Communication Standard (HCS) to adopt the GHS. This was done to improve the safety and health of workers through more effective communications on chemical hazards. The original standard was performance-oriented, allowing chemical manufacturers and importers to convey information on labels and material safety data sheets in whatever format they chose. The GHS provides a standardized approach, including detailed criteria for determining what hazardous effects a chemical poses, as well as standardized label elements assigned by hazard class and category. This will enhance both employer and worker comprehension of the hazards, which will help to ensure appropriate handling and safe use of workplace chemicals. Additionally, this standardized approach will allow for more of an apples-to-apples comparison of similar chemistries.
The new guidelines require the use of pictograms, signal words, and precautionary statements to communicate safety hazards and guide the use of personal protection equipment (PPE). These new requirements will appear on product labels as well as safety data sheets. Product SDSs and industrial/institutional labeling are requiredto be updated with the new hazard warnings by June 1, 2015. A phase-in transition allows employers to be in compliance with either the existing HCS or the revised HCS, or both.
OSHA estimates that the revised Hazard Communication Standards will result in the prevention of 43 fatalities and 585 injuries and illnesses (318 non-lost-workday injuries and illnesses, 203 lost-workday injuries and illnesses, and 64 chronicillnesses) annually. The monetized value of this reduction in occupational risks is an estimated $250 million a year on an annualized basis. It is also estimated that over 5 million workplaces in the United States would be affected by the revised Hazard Communication Standards. These are all those workplaces where employees — a total of approximately 43 million — could be exposed to hazardous chemicals.
Under GHS, labels will require the following elements:
• Pictogram: (see page 44) a symbol plus other graphic elements (such as a border, background pattern, or color) that are intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red diamond. There are nine pictograms under the GHS.
• Signal Words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are “danger” for more severe hazards, and “warning” for less severe hazards.
• Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
• Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling of a hazardous chemical.
GET TO KNOW THE NEW GHS PICTOGRAMS
It is important to understand that the use of these new pictograms may make it appear that some products are more hazardous than in the past, but products have not changed, the system for communicating the product hazard has changed.
There will also be changes to the MSDS (Material Safety Data Sheets), which will be renamed to SDS (Safety Data Sheets). The format is the same as the ANSI standard format, which is widely used in the United States and is already familiar to many employees. The new SDS requires that the information be presented using specific headings in a specified sequence, covering 16 sections:
Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical properties
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information
Section 13. Disposal considerations
Section 14. Transport information
Section 15. Regulatory information
Section 16. Other information, including date of preparation or last revision
TIMELINE FOR CHANGES
The table below summarizes the phase-in dates for GHS classification and labeling required under the revised Hazard Communication Standard (HCS) for manufacturers, distributors, and employers.
OSHA recognizes and allows that hazard communication programs will go through a period of time where labels and SDSs under both standards will be present in the workplace. This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.
It is important to know your next steps. It is a good idea to outline your compliance framework now, predetermining the roles and responsibilities at your business. There are a number of tools you can use to further familiarize yourself and your staff on the new GHS standards on the OSHA website including easy to use “Quick Cards” and videos for training your staff. The following will get you off to a good start:
Also, there are numerous third-party providers of GHS training specifically designed for small businesses that may be accessed through the web.
Megan Loch is vice president marketing for Zep Vehicle Care Inc.