OSHA Revises Hazard Communication Standard (TRN Safety Alert)

From Cliff Gerbick, ASP (The Reserves Network Director of Safety)

The Occupational Safety and Health Administration (OSHA) has revised its Hazard Communication Standard (29 CFR 1910.1200) to align it with the United Nations global chemical labeling system. In a process that began decades ago, OSHA has at last published the final rule that will update the current standard to mirror the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

The updates to the standard will provide chemical manufacturers a proscribed format for identifying the hazards associated with chemicals. Currently, OSHA requires all employers to maintain Material Safety Data Sheets (MSDS) for all hazardous chemicals in the workplace.

While this requirement will not change, the format in which MSDS are organized will be standardized and must contain the information in the following order:

Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-Aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical properties
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information
Section 13. Disposal considerations
Section 14. Transport information
Section 15. Regulatory information
Section 16. Other information, including date of preparation or last revision

In addition, OSHA is phasing out the use of MSDS and will now use the term Safety Data Sheet (SDS).

The other big change to the current standard is the standardized use of pictograms to identify the hazards associated with chemicals. There are nine pictograms used in the GHS and OSHA will adopt eight of them.  The ninth pictogram is in regards to environmental effects and since OSHA does not have jurisdiction overall environmental issues, it will not be used. The pictograms are:

HCS Pictograms and Hazards

Health Hazard

Flame

Exclamation Mark

• Carcinogen
• Mutagenicity
• Reproductive Toxicity
• Respiratory Sensitizer
• Target Organ Toxicity
• Aspiration Toxicity
• Flammables
• Pyrophorics
• Self-Heating
• Emits Flammable Gas
• Self-Reactives
• Organic Peroxides
• Irritant (skin and eye)
• Skin Sensitizer
• Acute Toxicity (harmful)
• Narcotic Effects
• Respiratory Tract Irritant
• Hazardous to Ozone Layer
(Non Mandatory)

Gas Cylinder

Corrosion

Exploding Bomb

• Gases under Pressure • Skin Corrosion/ burns
• Eye Damage
• Corrosive to Metals
• Explosives
• Self-Reactives
• Organic Peroxides

Flame over Circle

Environment
(Non Mandatory)

Skull and Crossbones

• Oxidizers • Aquatic Toxicity • Acute Toxicity (fatal or toxic)

OSHA has developed a timeline for all employers to be in compliance with the standard, culminating in 2016. The first deadline in the timeline, December 1, 2013, requires employers to train all employees on the new label elements (pictograms) and SDS format.

Other deadlines are as follows:

Effective Completion Date

Requirement(s)

Who

December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format. Employers
June 1, 2015

December 1, 2015

Compliance with all modified provisions of this final rule, except:
The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label.
Chemical manufacturers, importers, distributors and employers
June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers
Transition period to the Effective Completion Dates noted above. May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both. Chemical manufacturers, importers, distributors and employers

OSHA estimates the revised standard will prevent an estimated 585 injuries and illnesses annually. It will reduce trade barriers and result in estimated annualized benefits in productivity improvements for American businesses that regularly handle, store and use hazardous chemicals, as well as cost savings of $32.2 million for American businesses that periodically update safety data sheets and labels for chemicals covered under the standard.

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@trnstaffing.com.

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About TRNstaffing
The Reserves Network (TRN) is a family-owned, privately-held company that opened its doors in 1984. We have created a rich history of bringing employees and companies together by providing “Total Staffing Solutions.” Our office teams work with thousands of customers and job seekers offering Temporary, Temporary-to-Hire and Direct Hire placements to the Office, Industrial, Professional and Technical markets. Headquartered in Fairview Park, Ohio, the provider of "Total Staffing Solutions" has won multiple honors for outstanding sales growth and management excellence. System-wide, along with our Specialty Groups, TRN works with over 1,000 active customers in a multitude of industries and places nearly 20,000 employees annually at more than 40 operating locations throughout Ohio, Illinois, Georgia, Kentucky, Indiana, North Carolina, Florida, Pennsylvania, Wisconsin, Massachusetts, Rhode Island and Connecticut. For more information on The Reserves Network visit www.TRNstaffing.com

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