Are You Prepared? New OSHA Standard Requires Implementation Over The Next 3 Years!

A great deal of misinformation is circulating about how to comply with Occupational Safety and Health Administration (OSHA) now that its Hazard Communication Standard (HCS) has been revised to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  There are a number of important changes in the revised standard that require compliance actions by most companies.

The changes that impact most companies are:

• New Training Requirements—Note! Employee Training Deadline is December 1, 2013
• Updated Written Programs
• New Chemical Classifications
• New Labeling Elements
• New Safety Data Sheets (SDSs) Format

The program has a “phased-in implementation” through the middle of 2016 and is very high on OSHA’s priority list for compliance.  The first critical compliance date is December 1, 2013.  By that time, employers must have trained their workers on the new label elements and the updated SDS format.  OSHA states that this training is need early in the transition process since workers are already beginning to see the new labels and SDSs on the chemicals in their workplace.  Training will help employees know how to get the information they need to better protect themselves from chemical hazards in the workplace during the transition period. 

The list below provides a more detailed description of the minimum required topics for training that must be completed by the December deadline:

Training on label elements:

This training must include the type of information the employee would expect to see on the new labels, including the following items.

• Product Identifier – How the hazardous chemical is identified.  This can be (but is not limited to) the chemical name, code number, or batch number.  The manufacturer, importer, or distributor can decide the appropriate product identifier.  The same product identifier must be both on the label and in Section 1 of the SDS.
• Signal Word – used to indicate the relative level of severity of hazard and to alert the reader to a potential hazard on the label.  There are only two signal words, “Danger” and “Warning.”  Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards.  There will only be one signal word on the label no matter how many hazards a chemical may have.  If one of the hazards warrants a “Danger” signal word and another warrants a “Warning” signal word, then only “Danger” should appear on the label.
• Pictogram – OSHA’s required pictograms must be in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame sufficiently wide enough to be clearly visible.  A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label.  OSHA has designated eight pictograms under this standard for application to a hazard category.
• Hazard Statement(s) – describe the nature of the hazard(s) of a chemical, including the degree of the hazard when appropriate.  For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through skin.”  All of the applicable hazard statements must appear on the label.  Hazard statements may be combined where appropriate to reduce redundancies and improve readability.  The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it.
• Precautionary Statement(s) – means a phrase that describes recommended measures that should be take to minimize or prevent adverse side effects resulting from exposure to a hazardous chemical or improper storage or handling.
• Chemical Manufacturer, Importer or Distributor Information – name, address, and phone number for each product.
• Label Use in Workplace – how an employee uses the labels in the workplace.  For example, an employee must be able to explain how information on a label can be used to ensure proper storage of hazardous chemicals, as well as how the information on the label might be used to quickly locate information on first aid when needed.
• Element Interaction on Product Label – a general understanding of how the elements work together on a label.  For example, when a chemical has multiple hazards, different pictograms are used to identify the various hazards.  The employee should expect to see the appropriate pictogram for the corresponding hazard class.  If there are similar precautionary statements, the one providing the most protective information will be featured on the label.

Training on new format of SDS (formerly known as MSDS): 

This training must include the standardized 16-section format and how the information on the label relates to the SDS.

• Standardized Format – a 16-section format that includes the type of information found in various sections.  For example, the employee should be instructed that according to the new format, Section 8 (Exposure Controls & Personal Protection) will always contain information pertaining to exposure limits, engineering controls, and ways to protect himself.
• Label Information and the SDS – how information on the label is related to the SDS.  For example, explain that the precautionary statements would be the same on the label and on the SDS. 

Overwhelmed?  To assist you in meeting this deadline, American Compliance Systems (ACS) will be providing live Webinars!  ACS’s Webinars gives you:

• Access to live ACS professional staff for related questions.  All questions will be compiled, answered, and distributed to participating companies after the Webinar.
• Training record and certification for all employees that participate will be made available through our web-based recordkeeping system.

About American Compliance Systems (ACS):

ACS was founded in 1990 to provide products and services to help businesses manage workplace risk and maintain regulatory compliance. With over 22 years experience servicing virtually all market segments we have built a proprietary risk analysis system that complements our highly trained client services team, resulting in an optimal level of customer satisfaction. To field a Client Services Team to accommodate the extensive and varied needs of our client base, we recruit individuals from diverse educational backgrounds, with experience from a broad range of industries. Our proprietary risk analysis system empowers our service team with the most efficient and sophisticated tools available.