GHS and OSHA’s Revised Hazcom Standard: What You Need to Know

GHS Labeling

After all the talk, it’s finally here.  In this blog post I will discuss the revisions to OSHA’s Hazcom standard and how and when to comply.

GHS stands for “Globally Harmonized System”.  Developed by the United Nations, the idea was that how chemical information is handled needed to be standardized world-wide.  On March 26, 2012, OSHA published the revised Hazard Communication Standard, which is aligned with GHS Revision 3.  This final rule will take effect on May 25, 2012.

Major Changes in the Hazard Communication Standard include:

  1. Hazard classification: The revised standard provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
  2. Labeling: Chemical manufacturers and importers will be required to 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.
  3. Safety Data Sheets: Will now have a specified 16-section format and the name changes from Material Safety Data Sheet (MSDS) to Safety Data Sheet (SDS).
  4. Information and training: Employers are required to train workers by December 1, 2013 on the new labels elements and safety data sheets format to facilitate recognition and understanding

Let’s take a closer look at these changes.

Hazard Classification

Previously referred to as “hazard determination”, manufacturers and importers of chemicals are now required to perform hazard classification on their products.  In doing so, they must follow the requirements in Appendix A and B of the revised standard (both mandatory).  This is not a new requirement, but in the past this section of the standard was performance based, and it is now prescriptive.  This may mean that some companies will have to repeat this process in accordance with the guidance in Appendix A and B in order to be in compliance with the revised standard.   Employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer or importer for the chemical to satisfy this requirement.
Labeling

As of Dec. 1, 2015*, all labels will be required to have:

1. Pictograms
2. A signal word
3. Hazard and precautionary statements
4. The product identifier and supplier identification

*Employers have until June 1, 2016 to ensure that in-house labels have been updated.  All employees must be trained on new labeling requirements and pictograms by Dec. 1, 2013.  As of Dec. 1, 2015, manufacturers and importers may not ship products without the new labels.  Here’s an example of the new label:

Pictograms are mandatory to convey warnings to employees.  Here are the pictograms that you will need to incorporate into your labeling system and training program:
OSHA is requiring a red border on these pictograms so they will need to be printed in color.
Safety Data Sheets
Material Safety Data Sheets (MSDSs) become Safety Data Sheets (SDSs).  These new SDSs have a specific format, which must be followed to be compliant with the revised standard.

Section 1: Identification-includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.

Section 2: Hazard(s) identification-includes all hazards regarding the chemical; required label elements.

Section 3: Composition/information on ingredients-includes information on chemical ingredients; trade secret claims.

Section 4: First-aid measures-includes important symptoms/ effects, acute, delayed; required treatment.

Section 5: Fire-fighting measures-lists suitable extinguishing techniques, equipment; chemical hazards from fire.

Section 6: Accidental release measures-lists emergency procedures; protective equipment; proper methods of containment and cleanup.

Section 7: Handling and storage-lists precautions for safe handling and storage, including incompatibilities.

Section 8: Exposure controls/personal protection-lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).

Section 9: Physical and chemical properties-lists the chemical’s characteristics.

Section 10: Stability and reactivity-lists chemical stability and possibility of hazardous reactions.

Section 11: Toxicological information-includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.

Section 12: Ecological information

Section 13: Disposal considerations

Section 14: Transport information

Section 15: Regulatory information

Section 16: Other information-includes the date of preparation or last revision.

Note:  Since Sections 12-15 are enforced by other agencies, OSHA will not enforce these sections of the SDS.  Employees must be trained on the new SDS format by Dec. 1, 2013. New SDSs are required by June 1, 2015.

Written Program

Your written program must be revised to comply with the new standard including training, labeling, SDS management, and hazard classification.  Other updates may also be necessary if some of these required changed also change how you manage your Hazcom program.  Written programs must be updated  by June 1, 2016.

Other Hazcom Requirements

Other requirements of Hazcom stayed pretty much the same with the exception of some wording changes.  You can see the side-by-side comparison of the new standard and old standard here.

Summary

If you are an employer (that does not manufacture or import chemicals, but uses chemicals in the workplace), here’s what you need to do and when:

  1. Train employees on new labeling system, pictograms, and SDS format (by 12/1/13).
  2. Ensure that only new format SDSs are maintained (by 6/1/15).
  3. Ensure that products are not received without new labels (by 12/1/15).
  4. Update your labeling system using the new GHS system (by 6/1/16).
  5. Update your Hazcom program to reflect changes (by 6/1/16).
  6. Provide any additional training (such as updates to the Hazcom program-by 6/1/16).

If you manufacture or import chemicals, in addition to the above, you must also:

  1. Ensure that chemicals are properly classified according to the revised standard (by 6/1/15).
  2. Prepare SDSs in proper format (by 6/1/15).
  3. Prepare updated labels (cannot ship with old labels after Dec. 1, 2015.)

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