OSHA has updated its hazard communication standard (HazCom) to align with the United Nations’ Globally Harmonized System for the Classification and Labelling of Chemicals (GHS). At BLR’s recent Safety Summit, consultant and toxicologist Anne Chappelle of Critical Path Services advised participants to use HazCom to encourage management to make investments that benefit worker health and the bottom line. Keep reading to learn about her insights.
OSHA’s update is an effort to better classify and communicate chemical hazards. In general, Chappelle says OSHA is moving away from the “right-to-know” concept and toward the concept of “right-to-understand.” The standard addresses these basic categories:
- Chemical labeling,
- Safety data sheets (SDSs) (formerly material safety data sheets (MSDSs)),
- Hazard determination,
- Written implementation program,
- Employee training, and
- Process changes.
HazCom 2012 compliance basics
OSHA anticipates the revised standard, known as HazCom 2012, will prevent 43 fatalities and 521 injuries and illnesses annually, with a net savings of over $507 million a year.
The revised standard is expected to affect every U.S. workplace with exposure to hazardous chemicals. These changes will ultimately impact over five million facilities and over 40 million workers.
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GHS and Hazard Communication:
What Comes Next?
For companies that use chemicals (and do not manufacture, import, or distribute them), GHS compliance primarily centers around training. By December 1 of 2013, employers were required to train their workers to understand the new label format and 16-section SDS that will be gradually phased in as chemical manufacturers update their materials. When employers receive new labels and SDSs for chemicals they use, they must train workers on any newly identified hazards. Any necessary changes to secondary workplace labeling systems or written hazard communication plans must be completed by June 1, 2016.
For manufacturers, importers, and distributors of chemicals, the transition is more complex. In addition to establishing hazard communication programs for their workers, chemical manufacturers and importers employers also must:
- Identify the relevant data regarding the hazards of chemicals they produce or import;
- Review the data to determine the hazards associated with the chemical;
- Decide whether the chemical will be classified as hazardous according to OSHA’s definition;
- Determine the degree and category of hazard(s) by comparing the data with OSHA’s criteria for physical and health hazards;
- Reauthor all SDSs by June 1, 2015, using the new required 16-section format; and
- Create GHS-compliant labels (including signal word, pictograms, hazard statements, and other required elements) by June 1, 2015.
Chemical distributors have until December 1, 2015, to ensure that all shipments of chemical containers include GHS-compliant labels.
Benefits for the bottom line
GHS compliance can deliver much more than hazard protection, Chappelle advises. With the current business focus on sustainability, a strong GHS-compliant HazCom program demonstrates responsible product stewardship. SDSs represent an opportunity to help downstream customers comply with the law and protect employees. Making them as comprehensive and easy to use as possible provides good customer relations for the chemical producer.
As well, cleaning up a chemical inventory gives a company an opportunity to operate in a “greener” or more sustainable way by considering what hazardous chemicals are essential and which ones may be substituted for safer alternatives. It also offers a platform for communicating with executives about what chemicals are in use at a company’s facilities.
A comprehensive chemical review initiative helps identify new workplace hazards. Also, creating an orderly and up-to-date chemical list can be a good indicator to regulators that the rest of your safety and health program is orderly and compliant as well. And it provides a strong basis for chemical hazard training.