Can you identify this picture and explain to an OSHA inspector what it means?
If not, you may be facing OSHA fines during an OSHA inspection after December 1, 2013. The OSHA standard on hazard communication (HCS) Part 1910.1200, Title 29 of the Code of Federal Regulations, is a regulation originally promulgated in 19831. OSHA has now updated the HCS to align with the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS)2.
Every year the HCS is ranked as one of the most frequently cited OSHA standards across industries3. With the newly updated training requirement fast approaching, one would expect the HCS to maintain or even increase that ranking.
For all of us who have struggled to read chemical labels and Material Safety Data Sheets (MSDS) over the years, the standardization that the GHS brings is welcomed. So what changes does the GHS bring?
There are five major changes to the updated HCS.
- Manufacturers must provide criteria for classifying health and physical hazards and mixtures of chemicals.
- Manufacturers must revise labeling to include standardized signal words, pictograms, hazard statements, and precautionary statements.
- Manufacturers must revise Safety Data Sheets (SDS) – no longer called Material Safety Data Sheets (MSDS).
- Employers must train employees on the new elements of the HCS by 12/1/2013.
- These include:
- Employers and manufacturers must have a written plan for implementing the new requirements.
Even if employees have been previously trained on your facility HazCom program, ALL employees must be trained on these updated elements by December 12.
Manufacturer Label, Terms, and Pictograms
Every chemical must come with a unique manufacturer label which must include specific safety information. Employers must train on the meaning of this information and how to read the new label.
- Product Identifier/Name
- Manufacturer/Supplier Identification
- Signal Words DANGER or WARNING to alert users as to the level of hazard
- Hazard statement describing the nature and degree of the hazard
- Precautionary statements
There are 8 different pictograms that may appear on the label:
- Health Hazard
- Radioactive Toxicity
- Respiratory Sensitizer
- Target Organ Toxicity
- Aspiration Toxicity
- Emits Flammable Gas
- Organic Peroxides
- Exclamation Mark
- Irritant (skin and eye)
- Skin Sensitizer
- Acute Toxicity (harmful)
- Narcotic Effects
- Respiratory Tract Irritant
- Hazardous to Ozone Layer (Non-Mandatory)
- Skin Corrosion/Burns
- Eye Damage
- Corrosion to Metals
- Gas Cylinder
- Gasses Under Pressure
- Exploding Bomb
- Organic Peroxides
- Flame Over Circle
- Skull and Crossbones
- Acute Toxicity (fatal or toxic)
Training On the New Safety Data Sheets
The Safety Data Sheet (SDS), formerly known as Material Safety Data Sheet or MSDS, is an information form prepared by the manufacturer of a chemical.
The GHS requires the SDS format to include 16 standardized sections on which employees must be trained:
Section 1. Name/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 (lists the chemical’s characteristics)
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 the date of preparation or last revision
*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)).
When focusing on safety, do not forget to review, update and train employees on the facility HazCom Program including the new requirements of the HCS. Employees often work with chemicals on a daily basis, sometimes for years without ever looking at the chemicals’ labels or SDS/MSDS. Existing health problems such as asthma, dermatitis, or chemical sensitivities can be exacerbated by some chemicals. Employers must assure that employees read and understand the labels and SDSs for the chemicals with which they work, and utilize safety controls to protect themselves and others.
Modification of the Hazard Communication Standard (HCS) to conform with the United Nations’ (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS)
1) Occupational Safety and Health Standards- Toxic and Hazardous Substances
2) A Guide to The Globally Harmonized System of Classification and Labelling of Chemicals (GHS)
3) Most Frequently Cited Standards