Weekly Safety Meeting – New Hazard Communication Requirements

New Hazard Communication Requirements

In May of 2012, the Occupational Safety and Health Administration (OSHA) announced it was revising the Hazard Communication Standard (HCS). The revision aligns HCS with the United Nations’ global chemical labeling system or Global Harmonization System (GHS). The alignment will prevent an estimated 43 deaths and prevent an estimated 585 injuries and illnesses annually according to OSHA.

In addition to the safety and health benefits with this revision, there is also a financial benefit for businesses. This revision will result in an estimated $475.2 million in enhanced productivity for U.S. businesses each year. Furthermore, it reduces trade barriers for those businesses that regularly trade, store, and use hazardous chemicals.

So, what does this revision mean for the majority of U.S. businesses that do not produce and manufacture hazardous chemicals but use them or keep them on-site as part of the operation of the business?

Requirements:

To maintain compliance under the revised standard, a business first should conduct an inventory of all on-site hazardous chemicals. This action is beneficial as businesses can identify items that may be in the workplace that do not contain proper labeling. It is also an opportunity to identify items no longer used in the workplace that the employer can dispose. OSHA recommends employers conduct the inventory routinely or on a scheduled basis to keep up to date on hazardous chemicals entering the business. This helps prevent unwanted material from accumulating.

Once the inventory is complete, label all unlabeled hazardous chemicals found. Under the new HCS, workplace labels are no longer performance oriented but are standardized. The standardization includes the label elements listed below.

Signal words:

Based on the GHS criteria, only two signal words, ‘Danger’ and ‘Warning,’ remain. GHS drops ‘Caution.’

The signal word indicates the relative degree of severity of a hazard.

• ‘Danger,’ for the more severe hazards; and

• ‘Warning,’ for the less severe hazards.

Precautionary statements:

Standardized precautionary statements describe recommended measures to minimize or prevent adverse effects resulting from exposure, improper handling, or incorrect storage methods of a hazardous chemical.

Example: Wear face protection. First aid is included in precautionary information.

Pictograms:

These convey health, physical, and environmental hazard information assigned to a GHS hazard class and category. The GHS designates eight pictograms to identify a hazard category. Manufacturers and producers are already producing updated labels. Businesses will need to contact the manufacturers and producers for updated labeling.

Along with labeling, a safety data sheet (SDS) must accompany all the material identified in the inventory. Under the revised standard, SDSs replace material safety data sheets (MSDSs). SDSs provide a standardized order of information whereas MSDSs provide a detailed reference source on a hazardous material, but do not specify a format or order of information.

The new SDSs contain 16 headings:

1. Identification

2. Hazard identification

3. Composition/information on ingredients

4. First aid measures

5. Firefighting measures

6. Accidental release measures

7. Handling and storage

8. Exposure controls/personal protection

9. Physical and chemical properties

10. Stability and reactivity

11. Toxicological information

12. Ecological information

13. Disposal considerations

14. Transport information

15. Regulatory information

16. Other information

It will not regulate:

• Ecological information;

• Disposal considerations;

• Transport information; and

• Regulatory information.

Employers will need to update written HazCom programs to reflect the changes in the work environment brought about by the new regulations. Written programs should include how the facility implemented the standard, contain a list of all chemicals, address non-routine tasks ,and discuss contractors’ responsibilities.

Workplaces are expected to be fully compliant with the Revised Hazard Communication Standard as of June 1, 2016.

Ignoring a warning can cause much mourning!!