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Regulatory Spotlight

The federal government believes every American has the right to a safe workplace. In 1970, Congress created an agency charged with protecting that right: the Occupational Safety and Health Administration (OSHA).

OSHA is one of many agencies working to protect workers from the on-the-job injuries. Others include the National Institute of Occupational Safety and Health, the U.S. Department of Transportation and the Chemical Safety Board.

In this occasional series, we will spotlight regulatory initiatives and explain in layman’s terms how they affect you. Our first installment focuses on OSHA’s revised hazard communication standard.

Key terms

Hazard communication standard (HCS) – OSHA implemented the HCS to help protect workers from the hazards associated with certain chemicals. The HCS requires chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import, and to communicate those hazards to consumers.

Globally Harmonized System of Classification and Labeling of Chemicals (GHS) – The GHS is an internationally agreed-upon system for classifying and labeling hazardous chemicals. It is designed to replace the various classification and labeling standards used in different countries by using consistent criteria for classification and labeling on a global level.

Labels – Labels are informational elements concerning a hazardous chemical. They are affixed to, printed on or attached to the hazardous chemical container or its packaging. A label must explain why a chemical is hazardous and recommend preventive measures. A label must also include pictograms.

Pictograms represent the hazards associated with chemicals.

PictogramsPictograms are graphic symbols used to communicate specific information about the hazards of a chemical.

Safety data sheets (SDS) – An SDS is similar to a label, but it is more comprehensive. Workers should consult the SDS for information on the properties of each chemical; the physical, health, and environmental health hazards; protective measures; and safety precautions for handling, storing, and transporting the chemical. Under the previous hazard communication standard, safety data sheets were called material safety data sheets.

Why revise the HCS?

The old HCS allowed chemical manufacturers and importers to communicate information on labels and safety data sheets in a format they chose. The revised HCS provides a standardized approach to classifying the hazards and communicating the information. OSHA feels the revised HCS will better protect workers, particularly when they encounter chemicals produced in other countries.

What changed?

This chart provides a side-by-side comparison of the old HCS and the revised HCS. Major changes include:

Hazard classification – Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.

Hazard class number – Under the previous HCS, 0 represented the least-hazardous class, and 4 represented the most-hazardous. Under the revised HCS, 1 is the most-hazardous class, and 5 is the least- hazardous.

Labels – Chemical manufacturers and importers are required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.

Safety Data Sheets – Now have a specified 16-section format.

Information and training – Employers were required to train workers by December 1, 2013, on the new label elements and safety data sheet format.

When will the revised HCS be effective?

Chemical manufacturers have until Dec. 1, 2015, to comply with all components of the revised HCS. However, some have already begun shipping products that meet the new requirements.

Effective Completion Date Requirement(s) Who?
December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format. Employers
June 1, 2015 Compliance with all modified provisions of this final rule, except:

The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label – Effective December 1, 2015
Chemical manufacturers, importers, distributors and employers
June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers
Transition period to the effective completion dates noted above May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both. Chemical manufacturers, importers, distributors, and employers

What are employers’ training obligations?

OSHA required employers to train their employees on the new label elements and SDS format by Dec. 1, 2013. Texas Mutual recommends employers document all employee training. For more information about your training requirements, click here.

Need help?

OSHA’s HCS Web page provides more information on the revisions and what employers need to know.

OSHA created its “Small Entity Compliance Guide for Employers That Use Hazardous Chemicals” to help small employers comply with the revised HCS.

This chart provides key implementation dates employers need to know about.

About subject matter expert Al Capps

Texas Mutual safety services consultant Al Capps contributed to this blog post. Al is a professional engineer who previously served as an industrial hygienist for the Occupational Safety and Health Administration (OSHA). In that role, he conducted health and safety investigations, including air, noise and heat monitoring, as well as safety hazard recognition. Prior to joining OSHA, Al worked in the water quality division of the Texas Commission on Environmental Quality (TCEQ), where he conducted audits of municipal pretreatment programs, wastewater plan reviews and community outreach. As a Texas Mutual safety services consultant, Al partners with Central Texas employers to prevent workplace accidents and their associated costs. Al earned his bachelor’s degree in chemical engineering from the University of Texas.

OSHA feels the revised HCS will better protect workers, particularly when they encounter chemicals produced in other countries.