The Occupational Safety and Health Administration (OSHA) first issued its Hazard Communication Standard (HCS) in 1983. It was designed to ensure employees receive information about the health and physical hazards of the chemicals in their workplace and about how to protect themselves. HCS, which OSHA refers to as HazCom 2012, received a long-awaited facelift as of March 26, 2012, which became law 60 days later.
The HCS was put in place to help protect American workers from physical hazards (such as flammability, corrosion and reactivity) and health hazards (such as irritation, sensitivity and carcinogenicity) of chemicals used at the job site. By providing employees with this hazard information for chemicals to which they may be exposed, employers help them minimize risk. Chemical manufacturers and importers provide hazard information on container labels and more details are available on material safety data sheets (MSDSs).
One of the most frequently asked questions about updating the HCS was “why do it?” The United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) was the driving force behind the changes. This 1992 international agreement unified the world’s chemical hazard information so that all workers had access to the best data available. By adopting this mandate, the chemical hazard information will be of a higher quality and more consistent across international borders. The GHS will also help to reduce trade barriers; result in improvements to American business productivity for those that regularly handle, store and use hazardous chemicals; and provide cost savings for American businesses that periodically update MSDSs and chemical labels.
Although the HCS is merging with the GHS, not all of it will disappear. The basic framework of the HCS remains in place with four major changes:
• Hazard classification—The definitions for hazards have been altered to provide specific criteria for the classification of both health and physical hazards, including the classification of mixtures. This specificity ensures evaluations of hazardous effects are the same, regardless of manufacturer, and that the labels and data sheets are more accurate as a result.
• Safety data sheets (SDSs)—These will replace the MSDSs and will have a specified, 16-section format.
• Labels—Chemical manufacturers and importers will now be required to provide a label that includes a harmonized (or standardized) signal word, pictogram and hazard statement for each hazard class and category. Precautionary statements must also be included.
• Information and training—Even though training is part of HCS now, with the new system, employers are required to provide training on the new labels and SDS format to facilitate employee recognition and understanding.
Despite the fact that HazCom 2012 became law on May 25, all of the changes did not go into effect on that date. The revisions will be phased in over the next four years. This gradual introduction allows chemical manufacturers, importers and employers to get a handle on the new regulations in smaller doses. Theoretically, the revisions will result in greater compliance over time. It’s easier to process smaller changes several times than it is to accept substantial changes all at the same time. The time frame is as follows:
• On or before Dec. 1, 2013, all employers that use, handle and store chemicals will need an employee training program in place. It must include information on the new chemicals labeling system and SDSs. It is meant to familiarize employees with the new pictogram system on labels and what each of the 16 sections of the SDS means to them.
• The June 1, 2015, deadline affects chemical manufacturers, importers and distributors. At this time, they must comply with all the requirements of the GHS rule, except the voluntary compliance with the GHS label.
• Dec. 1, 2015, is when chemical manufacturers, importers and distributors must comply with the voluntary portion of the GHS labeling. By this time, all shipments of chemical containers must include the GHS-compliant labels that include signal words, pictograms, hazard statements and precautionary statements.
• On June 1, 2016, all employers that use, handle or store chemicals must be in full compliance with HazCom 2012. This includes the update of alternative workplace labeling and the hazard communication program as necessary as well as additional worker training for newly identified physical and health hazards.
During the transitional period, all chemical manufacturers, importers, distributors and employers can comply with the final standard (HazCom 2012), the standard as it is now or both.
The HCS has been referred to as the “right to know” standard. Ideally, this updated version will be viewed as an employee’s “right to understand” standard because it will clarify the hazards of chemical use, so they can better protect themselves.
KELLY is a safety and health specialist with Intec, a safety consulting, training and publishing firm that offers on-site assistance and produces manuals, training videos and software for contractors. She can be reached at 800.745.4818 and firstname.lastname@example.org. Joe O’Connor edited this article.