OSHA Aligns its Hazard Communication Standard with Globally Harmonized System

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A Brief Review of the OSHA Hazard Communication Standard Changes

Written by Henry P. Shotwell, Ph.D., CIH, Vice-President and Robert E.Sheriff, MS, CIH, CSP, President

November 26, 2018 

On March 26, 2012, OSHA finalized a rule which brings the OSHA Hazard Communication Standard (HCS) in line with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). OSHA’s Hazard Communication Standard, commonly understood to be the “Right-To-Know” standard, was originally promulgated in 1983.

On October 30, 2017 the secretariat of the United Nations published the 7th revision with the intention of insuring the Globally Harmonized System (GHS) to make the system more compatible with all nations of the world.

They have updated:

  1. Classification of flammable gasses.
  2. Extending Safety Data Sheets (SDS) usage on bulk cargoes.
  3. Labeling of small packages and containers with fold out labels.

This document is 534 pages and can be found at https://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/

Here are the major points that affect American businesses:

  • MSDSs will henceforth be called “Safety Data Sheets” (SDS). The new SDS will be standardized to have 16 sections:

1)      Identity of the supplier and the substance or mixture
2)      Identification of the hazards
3)      Information about the composition of the substance or mixture
4)      First Aid measures
5)      Firefighting measures
6)      Accidental release measures
7)      Handling and storage
8)      Exposure controls and personal protection
9)      Physical and chemical properties
10)   Solubility and reactivity
11)   Toxicological information
12)   Ecological information
13)   Disposal considerations
14)   Transport information
15)   Regulatory information
16)   Other information including information on preparation and revision of the SDS

  • By December 1, 2013, employers who are subject to the HCS (29 CFR 1910.1200) are required to have trained their employees on the new SDS format and label elements.
  • By June 1, 2015, chemical manufacturers, importers, distributors and employers must be in compliance with the new GHS changes.
  • After December 1, 2015, chemical containers cannot be shipped unless they have the new, GHS-compliant labels.
  • By June 1, 2016, all employers must have their hazard communication program updated to reflect the GHS modifications and their employees appropriately re-trained.

Why GHS? Many countries have regulations similar to the Hazard Communication Standard, but the differences in their requirements frequently require a chemical producer to affix two, three or even more labels when shipping abroad, in order to comply with the rules of other agencies, states and countries. Even in the United States, the Consumer Product Safety Commission, Department of Transportation, Environmental Protection Agency and the Occupational Safety and Health Administration each have different classification and label requirements. The GHS is an attempt to standardize these requirements throughout the world, so that anyone, anywhere in the world, could look at a single label and know the health and physical hazards of the container’s contents. This will both increase the level of worker protection and facilitate global trade of chemicals. OSHA also asserts the new standard will “result in cost savings to American businesses of more than $475 million in productivity improvements, fewer safety data sheet and label updates and simpler new hazard communication training.” https://www.osha.gov/dsg/hazcom/HCSFactsheet.html

What changes will be seen first? Labels will now carry specified signal words, hazard statements and symbols or pictograms. Standardized health hazard and physical property criteria will be used on Safety Data Sheets and on labels.  On September 19, 2016 OSHA published its labeling requirement that will satisfy OSHA and DOT requirement under the GHS for bulk shipments of hazardous chemicals see https://www.osha.gov/dsg/hazcom/joint_phmsa_memo_09192016.html.

OSHA in 2016 published an information document that updates the OSHA Hazard communication Requirements that are compatible with the Globally Harmonized System (GHS) in a 432 page document identified as OSHA 3844-02*2016 and can be found at https://www.osha.gov/Publications/OSHA3844.pdf.

Atlantic Environmental’s team of industrial hygiene and safety professionals are prepared to help guide you through the transition to the GHS modifications to your Hazard Communication Program. This includes revising annual hazard communication training requirements, updating written programs, and performing on-site training.

Our primary service areas for Hazard Communications are: NJ, NY, NYC, PA, CT, DE, (Boston) MA, RI, Wash DC, WI, MD, MI, (Chicago) IL, VA, IN, (Atlanta) GA, AL, NC, SC, TN, (Dallas, Ft Worth) TX, OK, DC, AR, we can service most other areas of the U.S. but with some added travel charges.