Countdown to GHS compliance
The first phase of new OSHA requirements for hazard communication goes into effect Dec. 1. Are your workers trained?
Safety Data Sheets
The other major component employees must be trained on is the SDS. (The name was changed from MSDS to be more consistent with the term used worldwide.)
“The data sheets are a more complex issue, but I honestly don’t know how many employees routinely request the data sheets,” Levine said.
Even still, employees must be trained on the format of SDSs. But simply giving employees a data sheet does not equal training, Levine warned – a stance OSHA has held since the original hazcom standard.
OSHA requires training to address the standardized 16-section format of the SDS:
Section 1: Identification, which includes elements found on the label such as product identifier and contact information
Section 2: Hazard identification of the label elements, including the signal word, hazard and precautionary statements, and pictogram
Section 3: Ingredient composition and information, which for substances includes the chemical name and its synonyms; for mixtures, the same details as required for substances, but also must specify the concentration of each ingredient
Section 4: First aid measures
Section 5: Firefighting measures
Section 6: Accidental release measures, including instructions for evacuations, containment methods and cleanup procedures
Section 7: Handling and storage guidance
Section 8: Exposure controls and personal protection, including permissible exposure limits, engineering controls and recommended personal protective equipment
Section 9: Physical and chemical properties, including its appearance, odor, flammability or explosive limits, and melting or freezing points
Section 10: Stability and reactivity of the chemical
Section 11: Toxicological information, which addresses the likely routes of exposure and a description of exposure effects
Sections 12-15 Non-mandatory sections that might include ecological information, disposal considerations, transportation information and regulatory information
Section 16: Other information, such as when the SDS was prepared or when a revision was made
Although the content within each of these sections may change depending on the material, the type of information conveyed by the individual sections will remain unchanged. For example, Section 4 will always contain first aid measures for the product and Section 7 will always address handling and storage guidance.
The biggest change to the SDSs, according to Levine, is the information one would expect to find on the label also will be on the SDS – such as the information in Section 2 – and the wording should be identical. This differs from previous requirements, in which many label elements did not have to appear on the SDS.
At press time, OSHA had not released information on how long the new training should last, but Levine suggested it could be as short as 30 minutes, depending on the type of questions employees ask. Employees may have several questions on the new requirements, and employers should be prepared to answer them, he said.
Some questions may include:
Regardless of who created the label, it will include a harmonized signal word, pictogram and hazard statement, as well as a precautionary statement. The SDSs will be in a specific 16-section format.
How soon will we see changes?
Changes to the labels and SDSs already may be seen, as manufacturers and distributors have been allowed to use them. However, the date for full compliance – when employees should see the new labels on everything – is June 1, 2015. Distributors are not allowed to ship containers with non-GHS-compliant labels beginning Dec. 1, 2015.
What is the difference between OSHA’s and the National Fire Protection Association’s hazard categories?
This is the area that may bring the most confusion, according to Baker. OSHA’s hazard category is a numerical system, ranking hazards based on their severity. A hazard category of 1 is more severe than 4. Manufacturers, for example, would use the hazard category to determine which hazard statements to include on the labels and SDSs.
NFPA’s chemical hazard rating system is inverted – 0 is the least severe and 4 is the most severe.
However, many workers may not be affected, Baker said, as the hazard category will not be found on the label.
Is it going to make things safer for me?
Likely yes, stakeholders say. The updated hazcom rule standardizes many elements, which will help employees become aware of hazards they should know about. For workers who are unable to read or understand what is written on the label, the pictogram will convey general information about the hazard of a product, which will allow the worker to take certain precautions.
“Now with the GHS, we can hope for better harmonization so that we’ll see more harmony and less confusion,” Baker said. “It is better for the industry and it is better for workers.”