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In May 2012, the Occupational Safety and Health Administration (OSHA) enacted changes to the Hazard Communication (HazCom) Standard. The goal is to align HazCom with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Through the use of labels and safety data sheets (SDSs), it provides a “common and coherent approach” for classifying chemicals and communicating information about hazards. Fortunately, much of the standard remains unchanged, but the labels and SDSs will require employer attention. To ease the transition, OSHA will phase in the specific requirements over the next several years. The first phase goes into effect Dec. 1, 2013.
Training remains a crucial component of the HazCom Standard, which is why the first compliance date deals with an employer’s obligation to have a training program in place that teaches employees about the new label elements and SDS format. This way, employees know how to properly interpret the information when the new labels and SDSs show up at the job site, which already may be happening.
The new requirements for labeling and SDSs include the following:
• The SDS will replace the material safety data sheet. The information is basically the same in both; the main difference is consistency. All SDSs will have the same 16 sections containing the same information, no matter where or by whom the sheet was prepared. This new format is designed to be more user-friendly. The information must be in English, but it may be presented in other languages as well.
• Sections 1–8 contain general chemical information, such as hazard identification, safe handling practices and emergency control measures (e.g., firefighting).
• Sections 9–11 and 16 cover scientific and technical information, including the substance’s physical and chemical properties, exposure control, stability and reactivity, and the date of preparation or last revision.
• Sections 12–15 also must be included; however, OSHA will not enforce the content because those sections are covered by other agencies, such as the Department of Transpiration and the Environmental Protection Agency. Sections 12–15 are there to allow for consistency with the GHS.
• During SDS preparation, no section may be left blank. If the preparer cannot find relevant information for a particular section, that must be stated.
• Labels, like SDSs, will be standardized to increase users’ comprehension. HazCom revisions are a move from a performance-based standard to one that has more structured requirements for labeling. Information about handling and a chemical’s hazards must be expressed on labels with visual notations to alert the user.
Labels contain a limited amount of information—mainly the specific hazards of the chemical. A chemical’s SDS is the more complete resource of its particular hazards. Labels must contain the following:
• A pictogram, which illustrates the physical, health and environmental warnings, is a black symbol on a white background surrounded by a red diamond.
• Name, address and phone number of the chemical manufacturer, importer or responsible party
• Product identifier such as the chemical name, code number or batch number
• Signal words, which indicate the severity of a hazard. “Danger” is used for more severe hazards; “warning” is used for less severe hazards.
• Hazard statements describe the chemical’s specific hazards. Any and all applicable statements must be included on the label. The wording is standardized, according to the GHS, so that the chemical user will always see the same statement for the same hazard, regardless of chemical or producer. Examples include “causes skin irritation” and “extremely flammable material.”
• Precautionary statements supplement the hazard statement and provide means to minimize or prevent the chemical’s adverse effects. These statements are also standardized according to the GHS and fall into four categories:
1. Prevention to minimize exposure
2. Response in case of accidental spillage or exposure
• Supplementary information is a catch-all for any additional information the label producer decides would be helpful.
While December is just the first deadline for HazCom 2012, it is the most significant deadline for contractors. The next deadlines, June 2015 and December 2015, deal mainly with manufacturer and importer compliance. By June 1, 2016, all employers must fully comply with the revised standard.