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September 16, 2013
HazCom's first compliance date is December 1. Do your workers understand?
By Ana Ellington, Legal Editor

Federal OSHA’s revised Hazard Communication (HazCom) Standard—also known as the workers’ right-to-know ruleis being hyped by OSHA as not simply the workers’ right to know, but the workers’ right to understand the hazardous chemicals they use and how to safely work with them.

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HazCom was revised to align with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). OSHA adopted these revisions effective May 25, 2012, that include GHS compliance requirements that will be phased in over a 4-year period with full implementation by June 1, 2016.

Two major changes to HazCom that affect employers and workers require (1) the use of new labeling elements and (2) a standardized 16-section format for safety data sheets (SDSs), formerly material safety data sheets (MSDSs). These are key in facilitating OSHA’s goal of workers’ right to know and understand. By December 1, 2013—the first compliance date—all your workers who are exposed to hazardous chemicals in the workplace must be trained on the new label elements and SDS format.

This training is needed early in the transition process, because workers will begin to see new labels and SDSs on chemicals in the workplace. As such, to ensure that your employees have the information they need to better protect themselves from chemical hazards in the workplace during the transition period, it is critical that your workers understand the new label and SDS formats.

This report will focus on the elements of the new standardized SDSs. For more information on the elements of the new labels, see our article GHS training deadline is approaching fast. Are your employees trained on the new labels?

Note: OSHA did not change the general requirements for workplace labels or secondary containers. Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical, or with label alternatives. Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 and the Hazardous Material Information System are permitted for workplace containers; however, the information supplied must be consistent with the revised HazCom.

Moreover, since these alternative labels would, at a minimum, provide only the product identifier and general information regarding the hazards of the chemicals, the employer must also make specific information regarding the physical and health hazards of the chemical immediately available to employees. Remember that workers need to know and understand.

Safety.BLR.com has everything you need to make the transition to GHS. Check out our GHS and Hazard Communication resource center for essential training materials, checklists, and more.

The New SDSs

Implementation of the GHS and the use of the SDS are expected to:

  • Create a safer workplace for you and your employees;
  • Reduce workplace accidents and illnesses caused by chemical exposures;
  • Provide consistent and simplified communications about substances and safe work practices;
  • Create greater awareness of hazards, resulting in safer use of chemicals in the workplace;
  • Make it easier and less costly for you to comply with HazCom regulations; and
  • Enhance the universal protection of human health and the environment.

The SDSs are prepared by the chemical manufacturer, importer, or distributor and describe:

  • Physical hazards, such as fire and explosion;
  • Health hazards, such as signs of exposure;
  • Routes of exposure;
  • Precautions for safe handling and use;
  • Emergency and first-aid procedures; and
  • Control measures.

Readily accessible

The SDSs must be readily accessible to your employees in their work area. Under 29 CFR 1910.1200(g)(8), electronic access and other alternatives to maintaining paper copies of the SDSs are permitted as long as no barriers to immediate employee access in each workplace are created by such options. OSHA interprets “readily accessible” to mean “immediate” and would consider a 2-hour interval between an employee’s request for an SDS and receipt of the information to fall short of this criterion.

Format: 16 sections

As of June 1, 2015, the revised HazCom will require new SDSs to be in a uniform format that includes the section numbers, the headings, and associated information under the following 16 headings:

  • 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)). See Appendix D of 29 CFR 1910.1200 for a detailed description of SDS contents.

For more GHS-compliant training resources, check out our GHS and Hazard Communication Resource Center.

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