Updated Hazard Communication
On March 20, 2012 OSHA released its final rule aligning the Hazard Communication Standard (1910.1200) with the United Nations Globally Harmonized System of classification and labeling of chemicals.
The new rule is intended to more easily communicate the hazards of substances through labels and Safety Data Sheets with a standardized approach that will use pictograms, signal words, and hazard and precautionary statements.
OSHA Administrator David Michaels said the idea of the original standard could be considered as the workers’ “right to know”, whereas the update gives workers the “right to understand”.
The final rule, scheduled for publication in the March 26, 2012 Federal Register will go into effect 60 days later. The rule’s requirements will go into effect in phases, beginning December 1, 2013 with the requirement that employees must be trained on the new label elements and Safety Data Sheet formats.
The table below summarizes the phase in dates required under the revised Hazard Communication Standard – HCS.
|
Effective Completion Date |
Requirement(s) |
Who |
|
December 1, 2013 |
Train employees on the new label elements and safety data sheet (SDS) format. |
Employers |
|
June 1, 2015* December 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 29 CFR 1910.1200 (the final standard), or the current standard, or both |
Chemical manufacturers, importers, distributors, and employers |
The OSHA Quick Card (below) highlights a sample revised Hazard Communication Standard label, identifying the required label elements which include pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier information. Supplemental information can also be provided on the label as needed.
Sample Label
Product Identifier
CODE ______________________________
Product Name ___________________
Supplier Identification
Company Name_________________
Street Address ______________________
City _________________ State ______
Postal Code __________ Country ______
Emergency Phone Number ___________
Precautionary Statements
Keep container tightly closed. Store in cool, well ventilated place that is locked.
Keep away from heat/sparks/open flame. No smoking.
Only use non-sparking tools.
Use explosion-proof electrical equipment.
Take precautionary measure against static discharge.
Ground and bond container and receiving equipment.
Do not breathe vapors.
Wear Protective gloves.
Do not eat, drink or smoke when using this product.
Wash hands thoroughly after handling.
Dispose of in accordance with local, regional, national, international regulations as specified.
In Case of Fire: use dry chemical (BC) or Carbon dioxide (CO2) fire extinguisher to extinguish.
First Aid
If exposed call Poison Center.
If on skin (on hair): Take off immediately any contaminated clothing. Rinse skin with water.
Hazard Pictograms
Signal Word
Danger
Hazard Statement
Highly flammable liquid and vapor.
May cause liver and kidney damage.
Supplemental Information
Directions for use
______________________________
______________________________
______________________________
Fill weight: ___________ _ Lot Number ______
Gross weight: __________ Fill Date: ______
Expiration Date: ___________
There is also an OSHA Quick Card (below) that highlights the updated Hazard Communication Safety Data Sheets, formerly known as Material Safety Data Sheets or MSDS. These must also be updated for all substances in the workplace, and must be maintained as of June 1, 2015.
Hazard Communication Safety Data Sheets
The Hazard Communication Standard (HCS) requires chemical manufacturers, distributors, or importers to provide Safety Data Sheets (SDSs) (formerly known as Material Safety Data Sheets or MSDSs) to communicate the hazards of hazardous chemical products. As of June 1, 2015, the HCS will require new SDSs to be in a uniform format, and include the section numbers, the headings, and associated information under the headings below:
Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.
Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.
Section 4, First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.
Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.
Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.
Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.
Section 8, Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
Section 9, Physical and chemical properties lists the chemical’s characteristics.
Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.
Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
Section 12, Ecological information*
Section 13, Disposal considerations*
Section 14, Transport information*
Section 15, Regulatory information*
Section 16, Other information, includes the date of preparation or last revision.
*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)).
Employers must ensure that SDSs are readily accessible to employees.
See Appendix D of 1910.1200 for a detailed description of SDS contents.
For more information: www.osha.gov
(800) 321-OSHA (6742)
U.S. Department of Labor
As of June 1, 2016, alternative workplace labeling and the Hazard Communication program must be updated as necessary with additional employee training provided for any newly identified physical or health hazards.
It is anticipated that the New Jersey Departments of Health and Labor will adopt the federal OSHA guidelines for the updated Hazard Communication Standard, including related enforcement activity.
The Statewide Insurance Fund’s Loss Control Department is monitoring OSHA’s update activity, and will provide information to its members accordingly. If you have any questions regarding the updated Hazard Communication standard and steps you should begin taking to ensure compliance, contact our office at 732-446-5958.
