Include Changes to OSHA HazCom Standard in Your 2013 Planning

Earlier this year the U.S. Department of Labor, Occupational Safety and Health Administration (OSHA) issued a final rule that revised its Hazard Communication (HazCom) Standard codified in OSHA’s General Industry Standards at 29 CFR §1910.1200.  The HazCom standard also applies to businesses that are covered under OSHA Standards for work in the Maritime (29 CFR Parts 1915, 1917 and 1918) and Construction (Part 1926) categories.  OSHA has estimated that over five (5) million workplaces across the United States will be affected by these revised regulations.

The HazCom Standard has been with us for over 25 years and requires that employers have a communication and training program that adequately informs workers about the hazards associated with any chemicals and products that they may be exposed to while on the job, using container labeling and other methods.  The HazCom Standard also requires manufacturers and importers to provide hazard information by developing and making available material safety data sheets (MSDS).  The HazCom regulation had not been significantly amended for many years and, in most workplaces, compliance efforts have become part of the normal course of business.  But now things will change.

OSHA has revised the HazCom Standard to make it conform to the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  Major changes to the HazCom Standard include the following:

• Hazard Classifications: There will now be specific criteria for each health and physical hazard and the HazCom Standard will also address mixtures.
• Labels: Every label must now have a Pictogram, signal words such as “danger” for severe hazards and “warning” for less severe hazards, a hazard statement and a precautionary statement.
• Safety Data Sheets: These will no longer be known as MSDS.  They are now Safety Data Sheets (SDS) and must be prepared in a 16-section standardized format.

If you took a quick look at the HazCom Standard revisions when they came out earlier this year, you might be thinking there is no rush.  It is true that compliance with the modified provisions of the rule pertaining to things such as label content and SDS format is not required until June 1, 2015.  However, employers are required to train their employees on the new label requirements and SDS format by no later than December 1, 2013.  Since in many workplaces annual employee training is done early in the calendar year, if the modified content is not included now, the new HazCom Standard training compliance date of December 1^st could easily be overlooked later in the year.  Don’t let that happen to you!