Major Changes to HazCom—OSHA Finalizes GHS

If you are a chemical manufacturer, importer, and/or distributer or an employer with hazardous chemicals in your workplace, the GHS is going to affect your operations. Here’s what you need to know.

Major Changes to the Hazard Communication Standard

Hazard Classification: There are specific criteria for the classification of health and physical hazards, but the big change here is the classification of mixtures.

Labels: Labels will include a harmonized signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.

Material Safety Data Sheets (MSDSs) to become Safety Data Sheets (SDSs): SDSs have a 16-section format.

Training: Workers must be trained on new labels and SDSs by December 1, 2013.

Important GHS Dates

OSHA is rolling out implementation of GHS over the next 4 years. Here are the deadlines:

December 1, 2013–Employees must be trained on the new labels and SDSs.

June 1, 2015–Chemical manufacturers, importers, distributors, and employers have to be in compliance with the all of the GHS requirements, except voluntary compliance with GHS label (you have until December 1, 2015 for this).

December 1, 2015–Chemical manufacturers, importers, and distributors must include the GHS-compliant label in all shipments of chemical containers.

June 1, 2016–All employers that use, handle, and store chemicals have to update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

GHS and Combustible Dust

At a media event held March 20, 2012, to announce the GHS, there were lots of inquires about the classification of combustible dust within the new GHS. The standard requires that combustible dust hazards be addressed on labels and safety data sheets (SDSs).

For more information on how to address combustible dust, Michaels referred to existing guidance, The Combustible Dust National Emphasis Program Directive CPL 03-00-008. The directive includes an operative definition, as well as provides information about current responsibilities in this area. In addition, there are a number of voluntary industry consensus standards (particularly those of the NFPA) that address combustible dust.

What’s Next On OSHA’s Agenda?

Dr. Michaels was also asked at the press event if this update to the Hazard Communication Standard was going to be the only significant rule OSHA will get to accomplish this year. 2012 being an election year I thought this was an interesting question. Michaels said that OSHA was hard at work on a lot of things–electrical power generation being one of the things in the pipeline. I guess we’ll wait and see.