Wednesday, March 28, 2012

OSHA Globally Harmonizes Hazard Communication Standard

On March 26th, OSHA published its final rules for amending the Hazard Communication standard (HCS) 29 CFR 1910.1200 to implement the United Nations' Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in the Federal Register, 3/26/12.

This new standard is intended to simplify hazard communication requirements. Within the US several federal agencies regulate the use and transportation of chemicals and each agency has its own hazard communication requirements, resulting in chemical producing or importing companies having to prepare duplicates sets of documents etc. to meet the various requirements. Companies doing business abroad have a greater problem since each country has its own hazard communication requirements. The principle idea behind the GHS changes is to provide a common framework for categorizing risks from chemicals and methods of labeling, and safety data sheets. Therefore the same labels or safety data sheets should meet the requirements around the world.

The new HCS will include classification of chemicals by hazard, new labeling requirements, employee training and safety data sheets.

Categorization of Chemicals
Under the GHS, each hazard (e.g., Explosives, Carcinogenicity) is considered to be a hazard class and the classes are generally sub-divided based on the degree of the hazard. For example, Carcinogenicity has two hazard categories. Category one is for known or presumed human carcinogens while category two encompasses suspected human carcinogens.

The hazard communication requirements under the GHS are directly based on the hazard classification. For each class and category of hazard, a harmonized signal word (e.g., Danger), pictogram (e.g., skull and crossbones), and hazard statement (e.g., Fatal if Swallowed) must be used. Thus, once a chemical is classified, the GHS provides the specific core information to convey to users of that chemical.

In addition to precautionary statements, labels will include up to eight different pictograms. Each of these pictograms consists of a different symbol in black on a white background within a red square frame set on a point (i.e., a red diamond). The specific pictograms to be used on a label are determined based on the hazard classification of the substance in question.

Safety Data Sheets
The GHS adopted the ANSI Z400.1 sixteen section format for the safety data sheet (SDS) (no longer called material safety data sheet). While many chemical suppliers already use this format, they are not currently required to. Chemical manufacturers and importers will have to re-evaluate chemicals to ensure they are classified appropriately. Chemicals will have to be assigned to the appropriate health hazard category as described above, and for their physical hazards. The criteria for physical hazards are generally consistent with current DOT requirements for transport.

The training requirements under the new standard are similar to the old other than to include the new GHS elements.

State Plans
Those States which have adopted their own plans in partnership with OSHA will have to update their plans within six months of publication of the final rule. Each State's existing requirements will continue to be in effect until it adopts the required revisions.

This rule becomes effective on May 25, 2012 and all employers will have to complete training of their employees by December 1, 2013. The new format labels and safety data sheets must be in place by June 1, 2015, however, distributors will have an additional six months (by December 1, 2015). In the interim employers will be considered to be in compliance as long as they are complying with either the existing Hazard Communication Standard or the new one.

This blog is a very short summary of the new hazard communication standard. For those people who want more information, OSHA has created a web page with more information, the Federal Register page mentioned above goes into great detail about the development of this new regulation; and OSHA has prepared a side by side comparison of the current HCS with the new one.

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