Chemical Communication: Revised OSHA Regs in September
OSHA is in the final rule stages of revising its Hazard Communication Standard—commonly referred to as the “Right-To-Know” regulation—to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
While the GHS itself is not a standard or regulation, it is a system that defines and classifies chemical hazards adopting a standard set of rules for communicating physical, health, and environmental hazards through a uniform format.
The purpose of GHS is to promote efficiency between countries and government agencies in disseminating chemical hazard information to users. For example, in the U.S. manufacturers and importers of chemicals are required to comply with multiple sets of regulations from agencies such as OSHA, the Environmental Protection Agency, Department of Transportation, and the Consumer Product Safety Commission. The benefits of GHS include improving worker health and safety, facilitating trade, reducing costs, and enhancing emergency response to chemical incidents.
Currently, U.S. employers using chemicals, chemical mixtures, and other hazardous substances are required under OSHA’s Hazard Communication Standard (HCS) to have a written program, ensure proper labeling of containers, acquire and maintain material safety data sheets, and inform employees through training on the hazards of the chemical products/hazardous substances used or encountered in their workplace. The revised HCS will preserve these elements but adapt them to the GHS system.
For example, material safety data sheets will have a standard 16 section format as opposed to today’s variation (some having 9 sections or more) and the word “material” will be dropped. Safety Data Sheets (SDSs) and labels will be required to have signal words such as “Danger” or “Warning” along with hazard pictograms depending upon the class and category of hazards.
OSHA’s final rule on the revised Hazard Communication Standard is scheduled to be published in September. A two-year transition period has been proposed for training with a three-year period for full implementation.
To meet the updated standard, employers should be prepared to:
- Acquire a GHS-compliant Safety Data Sheet for each chemical in their inventory and re-label chemical containers;
- Update their written hazard communication program; and
- Train employees on changes to the standard.