Last spring, federal OSHA made a major change to one of its most frequently cited standards when it published a revised Hazard Communication (HazCom) standard. This revision is in alignment with the Globally Harmonized System for the Classification and Labeling of Chemicals or GHS. GHS has been part of a decade-long global effort to develop consistency in chemical classification and how chemical hazards are communicated on labels and safety data sheets.
Prior to GHS, countries had various systems for classifying and labeling chemicals; in fact, multiple systems can exist within the same country. Worse yet, some countries had no system at all. Multiple systems have been costly for governments to regulate and enforce, expensive for businesses to comply with, and confusing for employees who need to understand the hazards of chemicals in order to work safely. For instance, if a business ordered the same chemical from three different manufacturers, each located in a different country, that chemical easily could have been classified and labeled as “flammable,” “very flammable,” and “extremely flammable.” It’s easy to see how this can lead to confusion.
One of the major changes that GHS makes to the HazCom standard is how chemicals are classified. Under the old standard, the basic obligation was to determine the hazards of each product, but the standard lacked any specifics about how this was to be done. Under the new standard, chemical manufacturers and distributors follow a prescribed method for classifying the health and physical hazards of chemicals based on available data about each chemical.
While the requirement to properly label chemicals will not change, the content of the label will. Labels will now require:
1. Product identification and hazardous ingredients
2. Supplier information (name, address, and phone number)
3. Hazard pictograms (symbols used to convey health, physical, and environmental hazard information that are assigned through classification)
4. Signal words (“danger” or “warning” are used to signify the relative severity level of the hazard)
5. Hazard statements (phrases that describe the nature of the hazard)
6. Precautionary statements (recommended measures that should be taken to minimize or prevent adverse effects from exposure, improper storage, or handling of hazardous chemicals)
The new pictograms, signal words, hazard statements, and precautionary statements for labeling combine to provide an internationally uniform system of communicating the physical and health hazards of chemicals to employees.
The third major change of GHS is the standardization of safety data sheets (SDS), formerly called material safety data sheets (MSDS). Previously, a lack of consistency in SDS meant that an employee needing to quickly find first aid information about a chemical might not know where to look in one of these multi-paged documents. Under the new system, this information will always be found under Section 4. In fact, it will now be mandatory to have a 16-section format with specific information assigned to each section.
Finally, OSHA requires that employers train their employees on the new label elements, the communication tools used to convey chemical hazards, as well as the new GHS-styled, 16-section SDS format.
At the federal level, all of these changes come with a phased-in transition period for required completion dates. As a state-administered OSHA plan state, Oregon OSHA had six months following the federal action to determine if it would adopt the federal changes or develop its own version that is “at least as effective as” the federal requirements. It was recently announced that Oregon OSHA would adopt the federal changes to its hazard communication rule and use the same phased-in transition period for compliance.
SAIF has developed a resource, titled “The Globally Harmonized System—Impacts for Hazard Communication,” that contains checklists to help you plan for these changes. In fact, we have an entire safety and health topic page dedicated to hazard communication and GHS.
This article is from the fall 2012 issue of Comp News. See other articles from this publication.