OSHA Hazard Communication Standard Revision

The Occupational Safety and Health Administration (OSHA) is requiring that all employees be trained, by December 1st of 2013, on the revision to its Hazard Communication Standard. The revision to the 1994 standard more closely aligns with the Globally Harmonized System (GHS), an international approach to labeling and classifying hazardous products.

Why the change? Credit the global marketplace. The U.S. is both a major importer and exporter of chemicals. American workers often see labels and material safety data sheets (MSDS) from the U.S. and from other countries. The diverse and sometimes conflicting national and international requirements can create confusion among those who seek to use hazardous material information effectively.

Major Changes
The Hazard Communication Standard regulates identification and communication of hazardous products in the workplace. The major changes include:

  • Hazard classification: There are now specific criteria for classification of health and physical hazards, to help ensure that evaluations of hazardous effects are consistent across product makers.
  • Labels: Chemical manufacturers and importers will be required to provide a label that includes the product name, supplier identification including an emergency phone number, the word "Warning" or "Danger," pictograms, and hazard statements for each hazard class and category. Precautionary statements must also be provided.

Safety Data Sheets: The word "Material" has been dropped, and there is a specified 16-section format. The previous standard had a nine-section material safety data sheet, but product makers could generally deviate from that as long as the information was there. Now all safety data sheets will be 16 sections.

If manufacturers, importers, distributors, or employers become newly aware of any significant information regarding the hazards of a chemical, the label should be revised to the new standard within six months of becoming aware of the new information. With products that have not changed, product makers have between June and December of 2015 to convert their labels and safety data sheets to the new standard.

Why the December 1st 2013 training requirement for employees if the product makers have until 2015 to implement the new standard requirements? OSHA believes that American workplaces will soon begin to receive labels and SDSs that are consistent with the GHS, since many American and foreign chemical manufacturers have already begun to produce GHS-compliant labels and SDSs. It's important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they will be familiar with them, understand how to use them, and be able to access the information effectively.

Label Requirements
The supplier must provide at least the following on every hazardous material label:

  • The product identifier (name)
  • A signal word, indicating the relative level of severity of the hazard, either "Danger" (more severe) or "Warning" (less severe)
  • Hazard statements assigned to each applicable hazard class or category, such as "Flammable" or "Carcinogen"
  • Pictograms, eight to choose from and one environmental hazard option
  • Precautionary statements stating what should be done to protect the worker from the hazard, such as "Respiratory protection required" or "Keep away from open flame"
  • Name, address, and telephone number of the product maker or importer or other responsible party

The eight pictograms are shown below.

pictogramsOne or more of these pictograms must be on supplier labels.

Note that the pictograms are all within a red diamond. There are two new pictograms, one indicating "Health Hazard" and one indicating "Explosive." Health Hazards include carcinogens, reproductive toxins, and other toxins that target a specific organ. Explosives have been separated from flammables. The Environment pictogram is non-mandatory, as OSHA does not oversee environmental hazards.

Workplace Labels
Workplace labels are mentioned in the revised standard, but nothing has really changed. The minimum requirements for a workplace label are still the product name and indications on the specific hazards of the product, using pictograms, phrases, or words, whatever is available and applicable. If pictograms and phrases are used, they should be consistent with the revised standard. Sources for the label can be as complicated as using labeling kits from a safety catalog, or as simple as writing the information directly and legibly on the container in permanent marker.

National Fire Protection Association (NFPA) labels, with the diamond shape and the color and numbering system, can be used as workplace labels, but there's an important difference in the numbering system used by the NFPA compared to the GHS. With the NFPA system, the higher the number the greater the hazard, so a "1" is the least severe hazard. With the GHS, it's just the opposite, the lower the number the more severe the hazard, so a "1" is the most severe hazard. When using the NFPA label as a workplace label, use the GHS numbering system. The numbers are often included in the SDS.

Safety Data Sheet (SDS)
The information required on the SDS remains essentially the same as that in the 1994 standard, except that the information must be presented using 16 specific headings in a specified sequence.

The format of the 16-section SDS should include the following sections:

  • Section 1. Identification
  • Section 2. Hazard(s) identification
  • Section 3. Composition/information on ingredients
  • Section 4. First-Aid measures
  • Section 5. Fire-fighting measures
  • Section 6. Accidental release measures
  • Section 7. Handling and storage
  • Section 8. Exposure controls/personal protection
  • Section 9. Physical and chemical properties
  • Section 10. Stability and reactivity
  • Section 11. Toxicological information
  • Section 12. Ecological information
  • Section 13. Disposal considerations
  • Section 14. Transport information
  • Section 15. Regulatory information
  • Section 16. Other information, including date of preparation or last revision

Note that although the headings for Sections “12” “15” are mandatory, OSHA will not enforce the content of these four sections because these sections are within other agencies' jurisdictions.

Employer's Responsibility
Repair facility owners and managers need to become familiar with the standard revisions and train their employees on recognizing the new labels and reading the new SDS versions by December 1st.

OSHA has some downloadable "quick cards" available for help with this training. Go to www.osha.gov.

Besides the general information, it's even more important that repair facility owners and managers explain how the hazardous communication procedures will change in the specific facility. If OSHA makes a visit, that is what they will be looking for; if employees know how to find and read the information on hazardous materials that they work with.

OSHA recently updated its Hazard Communication Standard, which covers requirements for labels, safety data sheets, and hazard material classifications. Several product makers have already begun using the new labeling and SDS system, so, OSHA is requiring employees be trained to recognize the new label and SDS format by December 1st, 2013.

Even more important than general information is for shop owners and managers to inform employees about how hazard communications will change in the repair facility.

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