OSHA Revises Hazard Communication Standard to Align with GHS

As of March 26, 2012, the U.S. Occupational Safety and Health Administration (OSHA) has revised the Hazard Communication Standard (HCS), aligning it with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This rule will be implemented in various phases, with full implementation by 2016. The goal is to reduce confusion about chemical hazards in the workplace, facilitate safety training, and improve understanding of hazards. The revised HCS will “classify chemicals according to their health and physical hazards, and establish consistent labels and safety data sheets for all chemicals made in the United States and imported from abroad.” During the transition period, chemical manufacturers, importers, distributors, and employers may comply with either 29 C.F.R. Part 1910.1200 (the final standard), the current standard, or both.

In its fact sheet, available online, OSHA lists the following major changes to the HCS:

• Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated HCS provides 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 (SDSs): The new format requires 16 specific sections, ensuring consistency in presentation of important protection information; and
• Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and SDS format, in addition to the current training requirements.

Modifications to the HCS include revised criteria for classification of chemical hazards; revised labeling provisions that include requirements for use of standardized signal words, pictograms, hazard statements, and precautionary statements; a specified format for SDSs; related revisions to definitions of terms used in the HCS, and requirements for employee training on labels and SDSs. The final rule also modifies provisions of other standards, including standards for flammable and combustible liquids, process safety management, and most substance-specific health standards to ensure consistency with the modified HCS requirements. OSHA states that the results of these modifications will be improved safety, facilitation of global harmonization of standards, and production of hundreds of millions of dollars in annual savings.

This long awaited Final Rule on the Hazard Communication Standard (HCS) is now available at http://www.osha.gov/dsg/hazcom/ghs-final-rule.html.

We are poised to assist you in this transition, from reviewing your chemical inventory, authoring your new MSDSs, training your employees, or managing the implementation. Call to schedule a Hazard Communication Standard audit and begin the implementation.