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Future of the hazard communication standard

May 1, 2011

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The next action for OSHA’s hazard communication standard will be a final rule, projected to be released in August. What exactly will happen on this date? When do I need to train my employees on any changes? Does OSHA recognize a European Union Material Safety Data Sheet?

Responding is Bob Ernst, associate editor, J.J. Keller & Associates Inc., Neenah, WI.

In 2003, the United Nations adopted the Globally Harmonized System of Classification and Labelling of Chemicals. GHS includes criteria for the classification of health, physical and environmental hazards, and specifies what information should be included on labels of hazardous chemicals and Safety Data Sheets.

But GHS itself is not a regulation, a treaty or a standard. It only establishes chemical hazard classifications and methods for how those hazards are to be communicated. Individual countries have to incorporate GHS into their regulatory systems.

In September 2009, OSHA published a proposed rulemaking to align the hazard communication standard with GHS. Based on the fall 2010 Unified Agenda, OSHA plans to release the revised final hazcom rule in August. If this occurs, the final rule would be published in the Federal Register, and will become “law” upon the “effective date” specified in the rule.

What will be the effect?

The “harmonization” of the hazcom standard to GHS would not affect most of the current responsibilities for employers. Any employer with hazardous chemicals in the workplace still would be required to have a written hazcom program, label containers in the workplace, provide access to MSDSs and train employees.

Currently, the hazcom standard is performance-oriented, in that it establishes requirements for labels and MSDSs but does not require a specific language or format to impart that information.

The revised standard would require a change in the definitions of some hazards, such as the current definitions of flammable and combustible liquids. Hazards would be divided into hazard classes, which would be further sub-divided into category of hazard. For instance, under current OSHA requirements, a chemical is either a carcinogen or it is not, but under GHS, there are two categories of carcinogenicity.

Container labeling also will change from a performance-oriented approach to one that uses specific label pictograms, phrases, hazard statements and precautionary statements.

The current standard has no mandated MSDS format or number of sections, but under the new standard, Safety Data Sheets will have to adopt a specified 16-section format, with specific information to be included in each section. Once the rule is published, it is anticipated OSHA will allow employers three years to comply with the SDS and labeling provisions, and two years to comply with the training requirements.

It also is expected that chemical manufacturers, importers and suppliers will have three years to comply with the labeling and SDS requirements, although many already are using the 16-section SDS format. As to whether OSHA “recognizes” the EU MSDS, or a GHS-style SDS, the short answer is: It is acceptable if it meets OSHA’s requirements. Currently, OSHA has no mandated MSDS format or number of sections. The current hazcom standard requires MSDSs to contain a minimum amount of information per 1910.1200(g)(2), including physical and chemical characteristics of the chemical; the potential for fire, explosion and reactivity; the signs and symptoms of exposure; precautions for safe handling and use; and emergency and first aid procedures.

As long as the EU data sheet covers all of the required information, it would be acceptable. Of course, when the hazcom standard final rule is released, everyone will have to adopt the 16-section SDS format, which is similar to the ANSI Z400.1 MSDS format.

Editor’s Note: This article represents the independent views of the author and should not be construed as National Safety Council endorsements.

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