Employers must train all affected workers on new Occupational Health and Safety Administration (OSHA) rules governing label elements and a standard format for safety data sheets (SDS) by December 1, 2013.
Although the new Hazard Communication Standard (HCS) does not go into effect until June 1, 2015, employees must be trained on the new HCS, which will require pictograms on labels alerting users of products’ chemical hazards.
OSHA’s HCS applies largely to general industry, shipyard, marine terminals, longshoring, and construction, in addition to virtually any employer with one employee and one hazardous chemical. Office workers who deal with hazardous material only in isolated instances are not covered.
OSHA estimates that more than five million US workplaces employing an estimated 43 million people will be affected by the revised HCS.
In terms of the training itself, employers must present all information in a manner and language that their employees can comprehend. For example, if an employer needs to communicate work instructions or other information in a language other than English, they must provide safety and health training in that language to employees. If an employee’s vocabulary is limited, then the training must account for it.
New label-element training needs to focus on the type of information employees should expect to see, including product identifiers, signal words (the difference between “danger” and “warning”), pictograms, and precautionary statements. In addition, training on the SDS must include a review of the new 16-section format, an explanation of how the information on the label relates to the information on the SDS, and a discussion of how the precautionary statements on both the label and SDS will be the same.
Joyce Long, MRC’s WFS Practice Leader, noted, “This is a significant change in the labeling of hazardous chemicals and a tight deadline for training compliance. As the number of imports with new labels will continue to rise, ensuring that employees are familiar with the labels, and will continue to safely handle such products, is vital to maintaining a culture of safety in our clients’ workplaces.”
OSHA published the new standard in March 2012 in an effort to align the US hazard communications standard with that of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
Chemical manufacturers and importers are required to evaluate the hazards of the chemicals they produce or import, and prepare labels and safety data sheets to convey the hazard information to their downstream customers. Many chemical manufacturers are already providing their customers with the new SDS as well as transitioning to the new GHS pictograms and labels.
The essential requirements of a hazard communication program include:
For more information on the revised OSHA hazard communication standard, read, Risk Alert — Revised OSHA Hazard Communication Standard Compliance Dates.