OSHA’s Newly Revised Hazard Communication Standard

The world of chemical hazard communication just got a little smaller. With the introduction of OSHA’s newly revised Hazard Communication Standard (HCS), America’s workforce is now communicating with the world as part of the Globally Harmonized System of Classifications and Labeling of Chemicals (GHS). Why you ask? Reasons for this change are noted in the Federal Register.

Within the U.S., several regulatory authorities exercise jurisdiction over chemical hazard communication. In addition to OSHA, the Department of Transportation (DOT) regulates 11 chemicals in transport; the Consumer Product Safety Commission (CPSC) regulates consumer products; and the Environmental Protection Agency (EPA) regulates pesticides, as well as exercising other authority over the labeling of chemicals under the Toxic Substances Control Act. Each of these regulatory authorities operates under different statutory mandates, and all have adopted distinct hazard communication requirements. Tracking and complying with the hazard communication requirements of different regulatory authorities is a burden for manufacturers, importers, distributors, and transporters engaged in commerce in the domestic arena. This burden is magnified by the need to develop multiple sets of labels and safety data sheets for each product in international trade. Small businesses have particular difficulty in coping with the complexities and costs involved.

OSHA’s revisions to the HCS will result in cost savings to American businesses of more than $475 million in productivity improvements. These savings will be realized through fewer safety data sheet and label updates, simpler new hazard communication training and reduce trade barriers by harmonizing with systems around the world.

What are the changes and how will they affect contractors?
The changes that will affect the employer (contractor) are to train employees on the new hazard classifications (pictograms), make employees aware of new labels on containers and the new Safety Data Sheet (SDS) format. There are no substantive changes to the written hazard communication program requirements; only some terminology has changed (e.g., Material Safety Data Sheets). These changes, however, will require employers to review their current Hazard Communication Program and identify old Material Safety Data Sheets (MSDSs) and replace them with the current SDS format sheets.

New Labels
Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category. Under the newly revised HCS, labels will require the following elements:

  • Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine
    pictograms under the GHS.
  • Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for less severe hazards.
  • Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
  • Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling of a hazardous chemical.

New Safety Data Sheets
The new format requires 16 specific sections, ensuring consistency in presentation of important protection information. The new SDSs will be required to communicate voluntary limits such as Threshold Limit Values (TLVs) as established by the American Conference of Governmental Industrial Hygienists (ACGIH), giving employers the option to provide protection which goes above OSHA’s minimal guidelines.

Information and training
To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format.

Need Help?
For additional information on the new Hazard Communication Standard, or for help in understanding how these changes will affect you, contact the friendly technical staff at the Construction Safety Council at (800) 552-7744.

Please click on the link below to view the January 2013 newsletter:
Arc Flash Newsletter 01/13