DID YOU KNOW?

According to OSHA, the purpose of the Hazard Communication Standard (HCS) is “to ensure that the hazards of all chemicals produced or imported are evaluated and details regarding their hazards are transmitted to employers and employees.” The premise behind HCS is that employers and employees have the right to know the hazards and identities of the chemicals they are exposed to and what precautions they can take to protect themselves.

OSHA’s phase-in period ended on June 1, 2016 for aligning its Hazard Communication Standard (HazCom) with the Globally Harmonized System (GHS), a global hazard communication system developed by the UN that standardizes the way hazardous chemicals are classified and then communicated via safety data sheets and labels.

Labels now have six standardized elements: product identifier, manufacturer information, signal word, pictograms, hazard statements and precautionary statements. Also under GHS, material safety data sheets (MSDSs) are referred to as safety data sheets (SDSs), the ‘M’ has been dropped. More importantly, these SDSs must now contain 16 sections in a specific order. Because of these changes, employers should expect to receive updated labels and SDSs with inbound shipments of chemicals, resulting in the eventual turnover of their entire safety data sheet library.

HCS violations consistently rank in the top 3 of OSHA’s ten most frequently cited standards list, with citations issued in nearly all industries.

Costs of non-compliance include:

• Fines
• Risk & Liability
• Downtime & Internal Disruption
• Negative Press & Damage to Corporate Image
• Lost Revenues

During an inspection, you will be asked to produce:

• Written HCS / HazCom Plan
• List / Inventory of Chemicals Used in the Workplace
• Evidence of Proper Labeling of Chemicals
• SDS / MSDS Documents & Details about Employee Access
• Information about Employee HazCom Training

Major changes to the Hazard Communication Standard

• Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
• Labels: 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.
• Safety Data Sheets: Will now have a specified 16-section format.
• 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.

Safety data sheets must provide comprehensive information about substances and mixtures used in workplaces. It’s worth noting that OSHA’s HazCom Standard refers to the GHS safety data sheets as material safety data sheets, or MSDS. They are an informational source about hazards and include safety precautions. They also assist employers in developing active programs for worker protection measures and training that are specific to the workplace and in considering the necessary measures for protecting the environment.

Over 30 million American workers are exposed to hazardous chemicals in their workplaces. The Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HCS) is intended to ensure that these workers and their employers are informed of the identities of these hazardous chemicals, associated health and safety hazards, and appropriate protective measures. The HCS covers some 650,000 hazardous chemical products found in over three million establishments.

Since the HCS was adopted 20 years ago, the availability of chemical information in workplaces has increased dramatically, and the provision of labels and MSDSs with products has become a standard business practice. Surveys have shown that employers rely on MSDSs to select less hazardous substitutes, as well as to help them identify appropriate protective measures. In addition to these workplace uses of hazard information, MSDSs have evolved into sources of information on other aspects of chemical use.

While the standard’s successes are evident, there are concerns regarding the quality of information disseminated under the HCS, in particular, whether the information is consistently accurate on MSDSs. This review examines the issues raised, as well as the underlying causes. It also describes a new OSHA hazard communication tool kit to address these issues that includes a balanced range of initiatives:

Substantive guidance to assist employers to evaluate hazards; provide worker training; and prepare MSDSs;

Implementation of an alliance with the Society for Chemical Hazard Communication, a professional society with expertise in the development of labels and MSDSs;

An enforcement initiative to identify critical information on a number of chemicals for OSHA’s compliance staff to use when reviewing MSDSs for those chemicals in the workplace, supplemented by development of an MSDS review tool and compliance staff training;

A portal page on OSHA’s web site that consolidates these and other hazard communication resources, and makes them accessible from a button on the home page; and,

Consideration of implementation of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) as a longer-term approach to improving hazard communication. The GHS includes provisions that address comprehensibility issues regarding hazard communication, including standardized approaches to labels and to MSDS format.