CHAD TISONIK
HNI Vice President

OSHA is changing its Hazard Communication Standard, and employers are required to train employees on the updated requirements by December 1.  The changes align OSHA's regulations with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), which is the international standard for labeling and clearly communicating chemical hazards to employees.  

GHS also provides rules on how employees are educated about chemical hazards. According to OSHA, changes to the standard will "prevent over 500 workplace injuries and illnesses and 43 fatalities annually" and will save American businesses more than $475 million in productivity improvements.

Label Requirements for the new OSHA Hazard Communication Standard

Employers need to label any container that does not already have a label. Containers directly purchased from the manufacturer or distributor now will include the required labels by law.

The new OSHA hazard communication standard says that labels for hazardous chemicals must contain the following:

• Name, address, and phone number of chemical manufacturer, importer, or other responsible party.
• Product identifier to describe how the hazardous chemical is identified. This could be the chemical name, batch number, or code number.
• Signal words to show the relative severity of the hazard. Only danger and warning can be used as signal words, with "danger" more severe than "warning."
• Hazard statements to describe nature and degree of hazard. According to OSHA, "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 statements to describe steps to minimize negative effects of hazardous chemicals. There are four types of precautionary statements: prevention, response, storage, and disposal.
• Pictograms to illustrate specific information about a hazardous chemical. GHS uses nine pictograms, but the OSHA hazard communication standard will use eight of the nine pictograms. (See image above.) Take note: According to OSHA, "a square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label."

The OSHA hazard communication standard pictograms do not replace the diamond-shaped labels required by the U.S. Department of Transportation for shipping chemicals.

New Format for Safety Data Sheets

Next, material safety data sheets (MSDS) now will be referred to as safety data sheets (SDS). The Hazard Communication Standard mandates that employers maintain a book of data sheets for all hazardous chemicals and make them available to employees.  This provision is included to ensure employees are aware of the chemicals to which they are exposed.  

Currently, there are a number of different formats for safety data sheets.  With the adoption of the GHS into the Hazard Communication Standard, however, employers will move to a single format which features 16 sections in a strict order.  

These new data sheets should be kept in a separate book, and, as always, one should be on file for all chemicals in your inventory. An online system for this can also be used.  Employees will need to be trained on the new safety data sheets and their sections (as well as any online or in-house storage system) by the December 1, 2013, compliance date.

Deadlines for Compliance with the New OSHA Hazard Communication Standard

Employers must train employees on the new label elements by December 1, 2013. By June 1, 2015, employers must meet all final modifications to the OSHA hazard communication standard.  Distributors may ship chemicals labeled by manufacturers under the old rules until December 1, 2015. 

By June 1, 2016, employers must update alternative workplace labeling and hazard communication as necessary and provide additional employee training for new health hazards. 

How are you staying up to date on OSHA compliance? What are your training strategies? Please share in comments!

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