4/29/13: The implementation of the revised Hazard Communication Standard is moving along and the first compliance date is December 1, 2013. By that time employers must have trained their workers on the new label elements and the SDS format. OSHA has recently updated the Hazard communication webpage and has added guidance specifically to address the upcoming training: http://www.osha.gov/dsg/hazcom/index.html
ABOUT: GHS (Globally harmonized System of Classification) was adopted by the United Nation (UN) as a guideline to create a standard of classification on Chemical Hazards. The Occupational Safety and Health Administration (OSHA) has adopted certain aspects of GHS into the newly modified Hazard Communication Standard (HCS). Unlike GHS, the HCS are required standards that must be met in order to comply with the law .Requirements for compliance can be found in the 4th edition of the “Purple Book”. From here we will refer the new standards as HCS.
BENEFITS: With the modification of HCS, OSHA believes the results will increase safety, health and promote efficiency in the workplace. Modifications will promote a reduction of accidents, fatalities, and injuries as a direct result from improper handling and exposures to hazardous chemicals. Through the use of the modified SDS’s, labels and employee training, employees will be able efficiently obtain information on a given product including chemical composition and hazardous associated. Expansion to include international trade can also be considered an additional benefit.
HOW WILL IT AFFECT ME? Under the new implementations of GHS manufacturers, suppliers, distributors and employers will all be affected. Rewriting and reformatting of MSDS to SDS will be required which includes a new 16 section format. New standards of labeling will also be enforced; labels must now include specific pictograms, signal words and hazard statements. The revised HCS also now provides specific criteria for health and physical hazards that will be applied both in SDS’s and labels. The newly adopted hazard classifications will allow for a more consistent and accurate evaluation of chemicals, mixtures and their effects. Employee training will also be implemented; employers are now required to train all employees on the new formats of SDS’s and labels. All new implementation of laws have mandated compliance dates with a final completion date of June 1, 2016.
EMPLOYEE TRAINING: To ensure compliance with HCS, employers are now required to train employees on the newly revised HCS. No set standard is required for training; however employers must insure that all employees are familiar with all new changes to labels and SDS. Employees should understand how to use them and how to effectively access information. OSHA requires compliance of employee training to be completed by Dec. 1, 2013.
SAFETY DATA SHEETS (SDS): Formerly called MSDS, the term SDS (Safety Data Sheets) was adopted in the new HCS. SDS’s are used to provide necessary information to employers and workers on chemicals hazards and safety precautions. The SDS also provides detailed information on the product including product identification, product composition, clean up procedures, etc. Prior to the new guidelines, MSDS were recommended to comply with a 12 section format; under the new GHS, a 16 section format is required.
GHS LABELS: Under new GHG guidelines all labels are to include additional information including:
|Effective Completion Date||Requirements||Who|
|December 1, 2013||Train employees on the new label elements and safety data sheet (SDS) format||Employers|
June 1, 2015*
Compliance with all modified provisions of this final rule, except:
The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label.
|Chemical manufacturers, importers, distributors and employers|
|June 1, 2016||Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.||Employers|
|Transition Period to the effective completion dates noted above||May comply with either 29CFR 1910.1200 (the final standard), or the current standard, or both.||Chemical manufacturers, importers, distributors, and employers|
The above information on GHS has been provided by Chemtel, Inc. Chemtel is also providing free of charge on their website a presentation to assist with training your employees under the GHS requirements. - Click here.