The Occupational Safety and Health Administration (OSHA) released its final revised Hazard Communication Standard (HCS) in March 2012. The revised Standard, which aligns with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS), will be fully implemented in 2016.
The revised HCS primarily affects manufacturers and importers of hazardous chemicals. The current HCS requires that chemical manufacturers and importers evaluate the chemicals they produce or import and provide hazard information to downstream employers and employees by placing labels on containers and preparing material safety data sheets (SDSs). All employers with hazardous chemicals in their workplaces are required to have a hazard communication program that includes employee training. The previous HCS established requirements for minimum information that must be included on labels and the SDSs but did not provide specific language to convey the information or offer a suggested format.
The revised HCS, however, makes significant changes to requirements on how hazard communication is to be carried out. Chemical manufacturers and importers of hazardous chemicals are required to re-evaluate chemicals according to the new criteria to ensure proper classification. These changes will help workers understand the chemical hazards that they might be exposed and become better trained in how to handle those chemicals safely. According to an OSHA fact sheet available here, the significant changes include:
Hazard classification: The revised HCS provides specific and detailed criteria to address health and physical hazards as well as classification of chemical mixtures. Under the revised HCS, a chemical will be classified based on the type, degree and severity of the hazard it poses.
Labels: Labels must include a signal word such as "danger," a pictogram such as "skull and crossbones," a hazard statement, and precautionary statement for each hazard class and category.
Safety data sheets: The revised HCS requires a new format for SDSs with 16 specific sections.
Information and training: In addition to current training requirement, workers must be trained by December 1, 2013 on the label and SDS changes.
Among other revisions made to the HCS is the creation of a category termed "Hazards Not Otherwise Classified" (HNOC). The revised HCS also includes combustible dust in the definition of "hazardous chemical."
" Employers are required to train their employees on the new labels and SDS changes by December 1, 2013."
As a means of ensuring proper execution, OSHA instituted a gradual phase-in process for implementation of the revised HCS. Employers are required to train their employees on the new labels and SDS changes by December 1, 2013. By June 2, 2015, employers, chemical manufacturers, importers and distributors must comply with all provisions of the revised HCS, with the exception that distributors may continue to ship products labeled under the old system until December 1, 2015. Finally, by June 1, 2016, employers must update their alternative workplace labeling and hazard communication programs as necessary and provide additional training to employees for any newly identified physical or health hazards. During the transition period between December 1, 2013 and June 1, 2016, all employers, chemical manufacturers, importers and distributors must comply with either the revised HCS, or the current HCS or both.
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