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Regulatory

Hazard Communication (as revised by the GHS)


The OSHA Hazard Communication Standard (HCS), among other things, regulates the labeling and safety data sheet (SDS) content of chemical products, including but not limited to cleaning chemicals. The HCS is intended to protect employees from the hazards of chemical products to which they may be exposed in the workplace.

GHS

In March 2012, the HCS was revised to be consistent with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS revisions to the HCS include, but are not limited to, the following:

  • Revised criteria for classification of chemical hazards;
  • Revised labeling elements that include requirements for use of standardized signal words, pictograms, hazard statements, and precautionary statements; and
  • A new, specified format for safety data sheets.

Hazard Communication (as revised by GHS): Topics and Resources

Effective Dates for GHS Revisions to HCS

The following summarizes the effective dates associated with the GHS revisions to the OSHA Hazard Communication Standard (HCS).

December 1, 2013: Employers (i.e., manufacturers, distributors, contract cleaners) are required to train their employees who may be exposed to hazardous chemicals regarding the new label elements and SDS format by December 1, 2013.

June 1, 2015: Manufacturers, importers, and employers must be in compliance with all GHS revisions including SDS and labeling revisions to the HCS by June 1, 2015. Distributors must be in compliance with the GHS SDS revisions by June 1, 2015.

December 1, 2015: After Dec. 1, 2015, distributors must be in compliance with the GHS labeling revisions, i.e., shipped containers of chemical products must be labeled consistent with the GHS revisions to the HCS.

June 1, 2016: All employers shall, as necessary, update any alternative workplace labeling used, update the hazard communication program required by the HCS, and provide any additional employee training for newly identified physical or health hazards no later than June 1, 2016.

Transition Period: Prior to the above effective dates, manufacturers, distributors, importers and employers may comply with either the “old” HCS or the HCS as revised by the GHS, or both during the transition period.

Hazard Classification

Under the GHS revisions to the Hazard Communication Standard (HCS), the hazard classification approach is quite different from the performance-oriented approach in the old HCS.

The HCS as revised by GHS has specific criteria for each health and physical hazard, along with detailed instructions for hazard evaluation and determinations as to whether mixtures of the substance are covered.

Mandatory Appendix A provides detailed guidance on the classification of Health Hazards; while mandatory Appendix B provide classification guidance for Physical Hazards.

Chemical manufacturers and importers must evaluate chemicals produced in their workplaces or imported by them to classify the chemicals in accordance with these appendices. For each chemical product, the chemical manufacturer or importer shall determine the hazard classes, and where appropriate, the category of each class that apply to the chemical being classified.

The hazard classification criteria set forth in the HCS as revised by the GHS is test method-neutral, i.e., the person classifying a chemical or substance should use available data and no additional testing is required to classify a chemical.

Resources

Safety Data Sheets

As revised by the GHS, the Hazard Communication Standard (HCS) requires that the manufacturer, distributor or importer provide downstream employers with Safety Data Sheets (SDSs) (formerly MSDSs or Material Safety Data Sheets) with the first shipment of a hazardous chemical product, and with the first shipment after a SDS has been updated.

New Format. The information contained in the SDS is largely the same as the MSDS, except now the SDSs are required to be presented in a consistent, 16-section format with a specified order.

The SDS includes information such as the properties of each chemical; the physical, health, and environmental health hazards; protective measures; and safety precautions for handling, storing, and transporting the chemical. The information contained in the SDS must be in English (although it may be in other languages as well).

As revised by the GHS, the HCS now requires that SDS preparers provide specific minimum information as detailed in Appendix D of the HCS.

SDS Resources.

GHS Labeling Elements

The labeling requirements of the Hazard Communication Standard as amended by GHS have been substantially revised. While, the old HCS took a performance-oriented approach to label content, the HCS as revised by the GHS sets forth detailed and specific provisions for labeling, leaving little to no discretion in the selection of content.

Of particular importance, the HCS as revised by GHS includes a new mandatory Appendix C (Allocation of Label Elements) that sets forth the specific content and information that must be provided on the label for each hazard class and category once a chemical is classified.

Label Content. Under the HCS as revised by the GHS, the labels of hazardous chemical products must contain the following information at a minimum:

  • Product identifier
  • Signal word
  • Hazard statement(s)
  • Pictograms
  • Precautionary statement(s)
  • Name, address, and telephone number of manufacturer or other responsible party

Labeling Resources

Employee Training and Education

The OSHA Hazard Communication Standard (HCS), as revised by GHS, requires all employers to train their employees regarding the new GHS label elements and Safety Data Sheet (SDS) format by Dec. 1, 2013.

Training Resources

Otherwise, the training provisions of the HCS as revised by GHS remain the same as in the old HCS, which are summarized below.

Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard is introduced into their work area.

Employees shall be informed of:

  • The requirements of the HCS;
  • Any operations in their work area where hazardous chemicals are present; and,
  • The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and safety data sheets required by this section.

In addition, employee training shall include at least:

  • Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as visual appearance or odor of hazardous chemicals when being released, etc.);
  • The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;
  • The measures employees can take to protect themselves from these hazards, including appropriate work practices, and personal protective equipment to be used; and,
  • The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information, and how employees can obtain and use the appropriate hazard information.

Written Hazard Communication Program

The OSHA Hazard Communication Standard (HCS) as revised by GHS has retained the exact same requirements regarding a written hazard communication program as set forth in the old HCS. These requirements are summarized below.

Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the employer will comply with the HCS requirements for labels and other forms of warning, safety data sheets, and employee information and training, and which also includes the following:

  • A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas); and,
     
  • The methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas.

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