Since 1985, the Hazard Communication Standard [29 Code of Federal Regulations (CFR) 1910.1200] has been the primary tool for providing employers and employees with information about the chemical hazards in their workplaces. Until the 2012 revision the performance-oriented standard allowed chemical manufacturers and importers to convey information on labels and material safety data sheets (MSDSs) in whatever format they desired. While the information has been helpful, a more standardized approach to classifying the hazards and conveying the information was needed.

Enter the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). GHS is an international approach to the classification of hazardous chemicals and the communication of hazards to workers via standardized shipped container labels and safety data sheets (SDSs). It is not a law; rather it is a system with components that countries can adopt into their own systems. The Occupational Safety and Health Administration (OSHA) adopted portions of the Third Edition of GHS into the Hazard Communication Standard on March 26, 2012. It was effective 60 days thereafter (May 25, 2012) and had a four year transition period.

The parts of the Hazard Communication Standard not related to GHS remained largely unchanged. These parts include the basic framework, scope and exemptions. The revised Standard still requires chemical manufacturers and importers to classify the chemicals they produce or import and to provide hazard information to employers and workers. It provides harmonized criteria for classifying chemicals according to their health and physical hazards, and requires specific label elements on shipped containers and mandatory standardized 16-section safety data sheets.

Major Changes

Definitions: In order to be consistent with GHS, some existing definitions were modified and/or deleted and replaced with new definitions.

Classification: Chemical manufacturers and importers are still required to determine the hazards of the chemicals they produce or import. The revised Standard provides specific hazard classification criteria to address health and physical hazards, as well as the classification of chemical mixtures.

Written Program: OSHA maintained the provisions of this section with no significant changes. However, existing written programs need to be modified to reflect new terminology, definition changes and labeling.

Labels: Chemical manufacturers and importers must provide a standardized shipped container label that includes a signal word, pictogram(s), hazard statement(s), product identifier, supplier identification and precautionary statement(s).

SDSs: Chemical manufacturers, importers or distributors must provide SDSs for each hazardous chemical to downstream users. The SDSs are presented in a standardized user-friendly, 16-section format.

Information and Training: Employers are required to 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 physical or health hazard is introduced into the area. The training must include methods and observations used to detect the presence or release of the chemical, physical and health hazards, protective measures, labeling and explanation of the SDS.

Benefits of the New Standard

The Hazard Communication Standard covers over 43 million workers who produce or handle hazardous chemicals in more than five million workplaces across the country. The revisions to the Standard were forecasted to prevent more than 500 workplace injuries and illnesses and 43 fatalities annually by helping:

Improve the quality and consistency of hazard information in the workplace, making it safer for workers to do their jobs and easier for employers to stay competitive.

Enhance worker comprehension of hazards, especially for low and limited-literacy workers, reduce confusion in the workplace, facilitate safety training that results in safer handling and use of chemicals.

Provide workers quicker and more efficient access to information on the SDSs.

Labels

What does the shipped container label look like and require? The shipped container label requires six items: product identifier, supplier identification, precautionary statement(s), pictogram(s), hazard statement(s) and signal word. The required six elements must be affixed to, printed on or attached to the immediate container of the chemical or to the outside packaging. Additionally, the signal word, hazard statement(s) and pictogram(s) must be grouped together on the shipped container label and not separated on the container or outside packaging

When it comes to workplace labeling, there are two options available:

• Label with the same information listed on the shipped container label; or
• Use of an alternate label method that provides general information regarding the physical and health hazards.

The revised Standard continues to allow employers the flexibility to use other alternate workplace labeling systems such as the National Fire Protection Association (NFPA) 704 diamond system or Hazardous Material Identifications System (HMIS). Any workplace labeling method may be used as long as the employee understands how to read the label and understand the hazards being communicated.