By Chuck Haling
From the May 2013 issue of Today’s Facility Manager
The clock is ticking on the time facility managers (fms) have to comply with the first deadline of the Occupational Health & Safety Administration (OSHA) revised Hazard Communication Standard (often referred to as HazCom 2012). Restructuring the standard brings it into alignment with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), the hazard communication system developed by the United Nations (UN). Any country or agency that adopts the GHS can adapt it to its needs and is entirely responsible for its enforcement.
The first HazCom 2012 deadline is December 1, 2013. That is the date by which employees in the United States who are exposed to hazardous chemicals must be trained on the GHS required changes to labels and material safety data sheets (MSDS).
Specifically, OSHA stipulates that employees who work with—or are otherwise exposed to—hazardous chemicals in the workplace must be familiar with the six new standardized label elements that are to appear on shipped containers. Additionally, OSHA says employees also must be updated on changes to safety data sheets, including an introduction to the numbering, ordering, and scope of the now standardized 16 section format.
High Level GHS Adoption
To understand HazCom 2012 training requirements it is helpful for fms to have background knowledge on how OSHA’s adoption of the GHS affects all stakeholders in the chemical life cycle, from chemical manufacturer through to employers.
The GHS was developed by the UN—with strong participation by OSHA and other U.S. agencies—to provide a global approach to defining and classifying chemical hazards, and to communicating those hazards via standardized safety data sheets and labels. When a country or agency like OSHA adopts the GHS, it takes only the GHS criteria and provisions that it deems appropriate and works them into its existing system (i.e., the HazCom Standard).
With OSHA’s adoption of the GHS, the changes begin with chemical manufacturers and distributors. These entities must reclassify chemicals using the OSHA approved GHS criteria for physical and health hazards. What qualifies as a physical or health hazard via GHS criteria is precise.
As a result, three hazards previously covered under the old HazCom Standard are not included. Those hazards are: combustible dust, simple asphyxiants, and pyrophoric gas. OSHA did not want to drop protections for these three hazards, so it changed the definition of hazardous chemicals to include them alongside the GHS defined physical and health hazards.
Classification is so specific and important in HazCom 2012 because of the new way classification information flows to the label and safety data sheet. In the past, OSHA required chemicals to be classified, but largely left it up to manufacturers and distributers to decide what information to put on the labels. Those days are nearing an end.
Prescriptive Approach To Labels
Under HazCom 2012, once a chemical is classified OSHA then prescribes the exact language and pictorial elements that are to appear on a shipped label. (This information also goes in Section two/Hazard Identification of the new safety data sheet.)
Following are the six required GHS elements for labels on shipped containers. These are the elements fms will need to train their affected employees on by the December 1, 2013 deadline.
- Product Identifier: Matches product identifier on safety data sheet
- Pictogram(s): Black hazard symbol on a white background with a red diamond border
- Signal Word: Either “Danger” or “Warning” depending on hazard severity
- Hazard Statement(s): Describing the nature and degree of the hazard(s)
- Precautionary Statement(s): Describing relevant prevention, response, storage, and spill measures
- Supplier Information: Including name, address, and phone number
OSHA expects that by the training deadline, employees in affected facilities will have an understanding of how these six elements work together, how the information can be used to handle products safely, and how label information can be used in cases of emergency.
Safety Data Sheet Makeover
Fms also need to train their employees by December 1 of this year on the new safety data sheet format. A HazCom 2012 compliant safety data sheet has 16 sections in a strict order. It is similar in layout to the ANSI standard for MSDSs.
Once every chemical manufacturer and distributor operating in the U.S. completes its chemical reclassifications and updates its safety data sheets, employees will know exactly where to find information on a safety data sheet, regardless of product or manufacturer. For example, Section four will always be First Aid Measures, and Section seven will always be Handling and Storage.
A cosmetic change to safety data sheets that may take some getting used to is their name change. Under HazCom 2012, safety data sheets are called SDSs. It is important to note that whether these are called MSDSs or SDSs, their essential purpose is unchanged. From that respect an MSDS and an SDS are really one and the same.
Employees should be trained to know that safety data sheets are structured so that the most important safety and emergency response information is located towards the front of the document while the more technical information is towards the back. Employees should also understand how the information in sections one and two on the safety data sheet relates back to the label.
With all of these changes to chemical classification and safety data sheets, fms should anticipate that their entire safety data sheet library will turn over in a relatively short time frame. With that in mind, fms should be thinking about their overall strategy of managing safety data sheets. Many facilities are turning to electronic management of safety data sheets to manage the influx and to ensure employees have access to the most up to date information possible.
Of course, updates can only happen as quickly as manufacturers make the necessary changes. Once changes are made, however, manufacturers are required to ship the updated safety data sheets with the next order to downstream users. If a facility no longer uses certain chemicals, fms should not expect to receive updated documents and labels without making a special request.
Conversely, if facilities receive chemical shipments with non-compliant SDSs after the June 2015 manufacturer deadline, OSHA will expect fms to make a good faith effort to secure the updated information. In this situation as well, a good electronic safety data sheet solution can provide concrete value.
HazCom Training Considerations
OSHA does not require trainers to have special certification to conduct HazCom training. It does, however, expect training to be effective—meaning that employees will be able to deliver what they have learned back into the workplace.
OSHA also strongly recommends that training records be kept. With HazCom violations ranking second on OSHA’s Top 10 List of Most Cited Standards, fms should expect that OSHA inspections going forward, especially after the December 1 deadline, will include a thorough look at employee training.
Fms seeking help with training, labels, or any other facet of HazCom 2012 compliance, will find there are resources online like free webinars and GHS compliance checklists that can help to make the transition a smoother one for a facility.
Rather than waiting until the last minute, fms should consider conducting the first round of training as soon as they responsibly can. Trained employees can serve as a first line of defense for identifying updated safety data sheets and labels as these enter the facility, and this preparation also gives fms a leg up for working on their overall HazCom compliance.
The second employer deadline is June 1, 2016. By that time, fms must have made any necessary updates to their facility HazCom programs and workplace labeling systems, along with having trained employees on any newly identified hazards as determined by the reclassification process.
Haling is the vice president of sales at MSDSonline, a Chicago, IL based provider of cloud based compliance solutions that helps businesses of all sizes cost-effectively manage global environmental, health, and safety regulatory requirements.