New Information from OSHA - Hazard Communication Update

 

What Is OSHA's Revised Hazard Communication Standard?

 

HazCom was revised in 2012 to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), providing consistent labels and 16-section Safety Data Sheets across facilities that manufacture, import, or use hazardous substances.

Also, it provides quick and visual information about health and physical hazards posed by chemicals worldwide with pictograms that conform to GHS.

Labels

The Hazard Communication Standard mandates that workplaces provide workers with information on the identities and hazards of chemicals to provide them with enough knowledge for selecting PPE and handling hazardous chemicals in the workplace, as well as reporting any illnesses associated with chemical exposure to their medical provider.

To meet this requirement, labels on chemical containers must display new GHS symbols and an individual hazard statement, consistent with those found on a 16-section Safety Data Sheet (SDS). Manufacturers, importers, and distributors should quickly update their labels and SDSs with regard to HCS revision.

Labels must incorporate pictograms and quick visual notations that support worker identification of hazards and comprehension across language barriers. Furthermore, labels should provide specific instruction on how to manage chemicals safely.

Prior to HazCom 2012 alignment, MSDSs could often be difficult to read and understand due to their inconsistent language, format, and organization. Now known as Safety Data Sheets (SDSs), these 16-section documents make reading and understanding much simpler.

The Hazard Communication Plan must be regularly revised when new chemicals or employees' job duties and locations change and reviewed every (period of time in months or years). Furthermore, training programs for employees should also be included as exposure or specific hazards change over time.

SDSs

Safety Data Sheets, or SDSs, are one of the cornerstones of an effective Hazard Communication Program. This type of document provides essential details about each chemical - its hazards, protective measures, and potential health impacts - making them essential to any written Hazard Communication Plan and should be readily available to all workers who handle chemicals. Previously known as Material Safety Data Sheets (MSDSs), since 2012 they must follow a uniform 16-section format containing information specific to hazardous materials in your workplace that include standardized signal words, pictograms, and hazard statements.

SDSs are required for every chemical your company produces, imports or transfers between facilities. You should also have one for any chemical you purchase or use at work and update its contents whenever new information becomes available. In addition to 16 sections, an SDS must also contain an executive summary page, chemical name and manufacturer contact info as well as an updated date in its footer.

OSHA inspectors will first look for evidence that your written program, chemical inventory, training records and employee access to SDSs have been properly managed - failure to do so could incur substantial fines for your business.

Inventory

Under HCS regulations, employees must have access to safety data sheets for every chemical they handle in a digital or printed format that makes them easily available - this ensures workers receive specific protection for real-world uses of chemicals. Failing to do this has been identified as one of the two most frequent violations under OSHA and has resulted in frequent citations against companies.

SDSs must now contain 16 sections organized uniformly that outline a chemical's hazards and provide instructions on how to safely handle it, providing quick reference guide sections designed for any worker, whether responding to an emergency or just gathering more information. In accordance with standard practice, employers are also obliged to maintain an inventory listing all chemicals with their labels in an area easily accessible to workers which should be regularly reviewed to reflect any changes in work environment or chemical handling processes.

Inventory should include product identifiers used on labels and SDS documents - this could include product or chemical names as well as anything that allows cross-referencing among various chemicals in an inventory. This allows safety professionals to keep an accurate record of which SDSs have been updated, while keeping accurate track of which have not.

Written Communication

Under the revised HCS, all chemical manufacturers and importers must classify each chemical according to its individual hazards, which must then be included on labels or SDSs as well as communicated to employees. A key component of the revised standard includes developing an in-depth written hazard communication program which addresses all aspects of such programs including:

A chemical inventory must be kept and managed, along with information on its handling. Updates should be performed regularly. In addition, an individual should be assigned the task of labeling, training and/or managing inventory levels in their facility.

All labels must now include pictograms, signal words and precautionary statements, as well as supplier information (name of supplier/code number or batch number listed in Section 1 of SDS) and product identification number (PIN). Furthermore, when removed from its original container for workplace use it must also be clearly labelled with this same information.

Employees should receive proper training on the new standards to enable them to understand labels and SDSs, both prior to implementation of these changes and as new chemicals are encountered. Interpretation services may also be provided if needed.