In a live chat held on July 11, OSHA answered questions on its recently published regulatory agenda including how the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS) will affect the hazard communication (hazcom) standard. The GHS includes harmonized provisions for classification of chemicals for their health, physical, and environmental effects, as well as for labels on containers and safety data sheets (SDS).
Many stakeholders are concerned about how much time they will have to comply with changes after the expected publication date in September. OSHA indicated that it proposed (September 30, 2009 proposed rule) a 3 year implementation period. During the rulemaking comment periods and at the public hearings, stakeholders submitted recommended implementation periods ranging from 3 to 15 years. OSHA is considering all of these comments and the implementation period will be announced when the final rule is published.
So what if you want to start preparing now? Will you still be in compliance with the current hazcom standard? Here’s how OSHA answered questions on this:
Q. Is it recommended that chemical manufacturers begin classification of its products according to GHS prior to finalization? Would there be a risk of over or under classifying?
A. A company may opt to classify the products according to GHS as long as it also follows the current hazard communication standard, and the company must assess whether the chemical is appropriately classified.
Q. We are already seeing GHS labels on some incoming products. Can I just add a GHS section on our current hazcom training to cover these labels and SDS?
A. Yes you may.
Q. Can we begin to author and distribute safety data sheets (SDSs) in the GHS format prior to the adoption of the final rule?
A. Yes, OSHA does not currently require a set format for the SDS. The GHS format is a commonly used format already.
Q. With GHS alignment, what is the minimum information required on a workplace or secondary container label?
A. OSHA did not propose any changes in the requirements for workplace labeling, and any changes in workplace labeling will be announced when the final rule is published.
Q. Has OSHA considered adding a language translation requirement to the regs on MSDS? If not, why not? If yes, what's the status of those considerations?
A. OSHA did not propose any changes in the language requirements in the hazard communication standard. However, GHS is designed to enable workers of limited literacy in the English language to understand the information.
All questions and answers in the live chat can be viewed on OSHA’s website.