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Revised Standard to Help Workers Better Understand Chemicals

On March 26, 2012, OSHA published its revised Hazard Communication Standard (29 CFR 1910.1200) to align with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

Keith Brown

Keith Brown

Safety Team Leader and Supervisor

The basic tenets of the Hazard Communication Standard (HCS) are not changing. Employers are still required to develop and implement effective written Hazard Communication programs, which include:

  • Identifying and documenting hazardous chemicals in the workplace
  • Maintaining and providing access to safety data sheets (SDS)
  • Establishing procedures for labeling containers of hazardous chemicals
  • Providing training on chemical hazards

The revised standard requires chemical manufacturers and importers to evaluate the chemicals they produce or import and provide hazard information to affected employers and employees by labeling containers and preparing safety data sheets.

Affected employers will be impacted by the need to adapt their written Hazard Communication Programs to reflect new terminology, update container labels, replace MSDSs with newly formatted SDSs and, perhaps most importantly, train employees on these changes.

The good news for most employers is that the standard allows for a multi-year transitional period for compliance. Employers covered by the standard must complete all training regarding the new label and SDS format by December 1, 2013. OSHA is requiring compliance with all provisions for preparation of new labels and safety data sheets by June 1, 2015. Distributors, however, will have an additional six months (by December 1, 2015) to distribute containers with manufacturers' labels in order to accommodate those they receive very close to the compliance date. Employers also will be given an additional year (by June 1, 2016) to update their hazard communication programs or any other workplace signs, if applicable.

Following are excerpts from the Federal Register, as published on March 26:

  • “The HCS (Hazard Communication Standard) requires a comprehensive hazard evaluation and communication process, aimed at ensuring that the hazards of all chemicals are evaluated, and also requires that the information concerning chemical hazards and necessary protective measures is properly transmitted to employees. The HCS achieves this goal by requiring chemical manufacturers and importers to review available scientific evidence concerning the physical and health hazards of the chemicals they produce or import to determine if they are hazardous.
    • For every chemical found to be hazardous, the chemical manufacturer or importer must develop a container label and an SDS, and provide both documents to downstream users of the chemical.
    • All employers with employees exposed to hazardous chemicals must develop a hazard communication program, and ensure that exposed employees are provided with labels, access to SDSs, and training on the hazardous chemicals in their workplace.”
  • “There are three information communication components in this system—labels, SDSs, and employee training, all of which are essential to the effective functioning of the program.
    • Labels provide a brief, but immediate and conspicuous, summary of hazard information at the site where the chemical is used.
    • SDSs provide detailed technical information and serve as a reference source for exposed employees, industrial hygienists, safety professionals, emergency responders, health care professionals, and other interested parties.
    • Training is designed to ensure that employees understand the chemical hazards in their workplace and are aware of protective measures to follow. Labels, SDSs, and training are complementary parts of a comprehensive hazard communication program—each element reinforces the knowledge necessary for effective protection of employees.
  • "Information required by the HCS reduces the incidence of chemical-related illnesses and injuries by enabling employers and employees to implement protective measures in the workplace. Employers can select less hazardous chemical alternatives and ensure that appropriate engineering controls, work practices, and personal protective equipment are in place. Improved understanding of chemical hazards by supervisory personnel results in safer handling of hazardous substances, as well as proper storage and housekeeping measures.”
  • “Employees provided with information and training on chemical hazards are able to fully participate in the protective measures instituted in their workplaces. Knowledgeable employees can take the steps required to work safely with chemicals, and are able to determine what actions are necessary if an emergency occurs. Information on chronic effects of exposure to hazardous chemicals helps employees recognize signs and symptoms of chronic disease and seek early treatment. Information provided under the HCS also enables health and safety professionals to provide better services to exposed employees. Medical surveillance, exposure monitoring, and other services are enhanced by the ready availability of health and safety information. The modifications that make up this final rule build on these core principles by establishing a more detailed and consistent classification system and requiring uniform labels and SDSs, which will better ensure that workers are informed and adequately protected from chemical exposures.”

OSHA has concluded that the revision significantly improves the current HCS standard. Moreover, there is widespread agreement that aligning the HCS with the GHS will establish a valuable, systematic approach for employers to evaluate workplace hazards and provide employees with consistent information regarding the hazards they encounter. A member of the United Steel Workers summed up the revision by stating that “the HCS in 1983 gave the workers the `right to know' but the GHS will give the workers the `right to understand'.”

If you have questions about how this revision affects your company, or to receive a free consultation to help you comply with the standard, contact USF SafetyFlorida at www.usfsafetyflorida.com. To read the standard in its entirety, click here. https://www.federalregister.gov/articles/2012/03/26/2012-4826/hazard-communication