Is your company in compliance with the new hazard communication standard requiring employee training to be completed within the next three months?
The Occupational Safety and Health Administration (OSHA) plans on fully implementing the revised standard by June 1, 2016. However, by Dec. 1, 2013, employers are expected to have trained workers on the new label elements and safety data sheet (SDS) formats required under the standard.
By Dec. 1, all U.S. employees who come into contact with chemicals in the workplace will have to be trained on how to interpret hazards communicated through brand new labels and pictograms as well as standardized safety data sheets.
“Over 5 million businesses will be impacted by the new requirements for labeling and data sheets,” said Marie Athey, an environmental health and safety (EHS) expert and director of EHS product management for 360training.com, a provider of online health and safety training.
“But employers should relax,” said Athey, because unlike comprehensive hazard communication training, the only two things OSHA wants employers to focus on for the Dec. 1 deadline is training employees on the new labels and the new safety data sheets.
The December deadline is the first of several under the revised standard over the next three years. The next deadlines are:
June 1, 2015: Chemical manufacturers, importers, distributors and employers must comply with all other requirements of the revised standard.
Dec. 1, 2015: Distributors may not ship containers unless they contain approved labels.
June 1, 2016: Employers must update workplace labeling and hazard communication programs as necessary, including additional employee training for newly identified chemical hazards.
Why All the Fuss About Hazard Communication?
Hazard communication has been one of the most frequently cited standards by OSHA for years. In fiscal year 2012, it was the most frequently cited standard for general industry.
In March 2012, OSHA revised its hazard communication standard to align it with the U.N. Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS is an international approach to standardizing hazard communication. “These changes will help ensure improved quality and consistency in the classification and labeling of all chemicals, and will also enhance worker comprehension,” an OSHA statement said.
Why does this training have to be completed this year if other parts of the standard don’t kick in until 2015? “There are already some countries that have adopted GHS, including those in the European Union, the United Kingdom and China, so we’re already seeing the new labels and new data sheets being used,” said Athey.
Employees need to know how to use the new documentation. Until the new standard takes effect in 2015, companies can use either old labeling and safety data sheets or the new versions.
What Has Not Changed
The new hazard communication standard does not change the basic requirements for employers, such as ensuring that labels on incoming containers of hazardous chemicals are not removed or defaced, maintaining safety data sheets and ensuring that they are readily accessible to employees during each work shift.
The revised standard also still requires that employers develop, implement and maintain a written hazard communication program.
The standard requires chemical manufacturers, importers or distributors to ensure that each container of hazardous chemicals is labeled, tagged or marked with the following information: product identifier; signal word; hazard statement(s); precautionary statement(s); pictogram(s); and name, address and telephone number of the chemical manufacturer, importer or other responsible party.
OSHA expects employers to train workers on understanding these label elements. Training on the standard should include the effective use of labels, for example, to locate needed first aid information, and explain how label elements may overlap, such as multiple hazards identified via pictograms.
The six elements in more detail:
The product identifier. This includes, for example, the chemical name, code number or batch number. This is given by the manufacturer, importer or distributor. The product identifier must be the same on the label and in Section 1 of the SDS.
Signal words. One of two signal words will be used to indicate the relative level of hazard severity: “danger” or “warning.” Within a specific hazard class, “danger” is used for the more severe hazards, and “warning” is used for the less severe hazards, said Athey. Only one word will be used on the label, regardless of how many hazards the chemical may have, and it must always be the highest-level severity word, she said.
Pictograms. There are nine OSHA designated pictograms, of which eight are mandatory:
• Health hazard.
• Exclamation mark, representing skin and eye irritant.
• Gas cylinder, representing gases under pressure.
• Exploding bomb.
• Flame over circle, representing oxidizers.
• Skull and crossbones, representing acute toxicity, possibly fatal.
• Environment, representing aquatic toxicity (nonmandatory).
There may be one, two, three or several pictograms on the label, said Athey.
OSHA’s required pictograms must be in the shape of a diamond and include a black hazard symbol on a white background with a red frame. A red frame without a hazard symbol will not be acceptable. “It has to have a pictogram inside it to be compliant,” said Athey.
Hazard statement. This describes the nature of the hazard of a chemical, including the degree of hazard, if appropriate. An example would be “Causes damage to kidneys through prolonged exposure to skin.”
Precautionary statement. This describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage and handling.
The name, address and phone number of the chemical manufacturer, distributor or importer. “This is very important if a label is damaged or missing an SDS sheet, so you can contact the manufacturer to get that additional information,” Athey said.
Labels must be legible, in English and prominently displayed. Other languages may be displayed in addition to English. Chemical manufacturers, importers and distributors who become newly aware of any significant information regarding the hazards of a chemical must revise the label within six months, OSHA said.
Safety Data Sheets
Another of the revised hazard communication standard’s significant changes is the replacement of the current material safety data sheet reporting format with standardized safety data sheets. These will cover everything from the chemicals’ potential hazards, first aid measures and how to control exposure, transport and disposal of the material.
“You may already be seeing this new format, because some countries have already adopted it and begun following it,” Athey said.
To be compliant, the safety data sheets should contain 16 sections and provide a description of the data used to identify hazards. The 16 sections are:
• Identification of supplier.
• Hazard(s) identification.
• Composition/information on ingredients. This includes mixtures and trade secret claims.
• First-aid measures. “Probably the first thing I’d train my employees on,” Athey said.
• Fire-fighting measures.
• Accidental release measures. “This is something that will happen in the workplace, so be prepared,” she said.
• Handling and storage. This section includes incompatibilities, such as ammonia and bleach, which creates a toxic gas when mixed together.
• Exposure controls/personal protection. Permissible exposure limits will be listed here.
• Physical and chemical properties.
• Stability and reactivity. Another important section when it comes to storage, said Athey.
• Toxicological information.
• Ecological information.
• Disposal considerations.
• Transport information.
• Regulatory information.
• Other information, including date of preparation or last revision.
“You will have to train your employees to understand that the information on the label is related to the SDS. For example, the precautionary statements should be the same on both,” said Athey.
Are You in Compliance?
With the potential of stepped-up hazard communication inspections starting after Dec. 1, employers must ask themselves: Is my hazard communication program in compliance?
For the answer to be yes, Athey said, “you have to have a written hazard communication plan in place.”
A written plan should, at a minimum, include lists of hazardous chemicals present; labeling of containers of chemicals in the workplace, as well as of containers of chemicals being shipped to other workplaces; preparation and distribution of safety data sheets to employees; and development and implementation of employee training programs regarding hazards of chemicals and protective measures.
Hazard Communication Standard Guides
OSHA has updated its hazard communication page to help employers make the transition to being compliant with the revised standard. Helpful publications include a fact sheet that covers the standard’s training requirements and a brief that the agency created explaining labels and their elements, what pictograms are and how to use them.
“Just throwing these OSHA resources at your employees in no way constitutes training. You’ve got to present information in the manner and language that your workers can understand, taking into account those employees that don’t speak English, have limited vocabulary or are illiterate,” Athey said. “Make sure that you’re overcoming training limitations or it doesn’t make any sense to do the training at all and won’t satisfy the training requirements.”
Roy Maurer is an online editor/manager for SHRM. Follow him on Twitter @SHRMRoy.