A few years ago we wrote a blog article that summarized the "new" OSHA Hazard Communication/GHS requirements. This summary included OSHA's decision to phase in the various required elements and a listing of the associated deadlines. We thought that we should revisit this topic now that the final deadline (June 1, 2016) has passed.
For starters, it's important to remember that OSHA's Hazard Communication/GHS Standard applies to companies that handle hazardous chemicals. While some of the required elements focus on chemical manufacturers, others apply broadly to hazardous chemical handlers.
The key requirements of the Hazard Communication/GHS Standard follow:
- Hazard Classifications: all chemical manufacturers and importers use the same criteria to classify the physical and health hazards associated with their chemicals
- Hazard Labels - Chemical Manufacturers: the following information is required on hazard labels generated by a chemical manufacturer or importer:
- Product identifier
- Signal word ("danger" or "warning")
- Hazard statement (eg., "flammable gas", "causes serious eye damage")
- Pictogram (see the graphic that accompanies this article)
- Precautionary statement (eg., "explosion risk in case of fire", "do not induce vomiting")
- Name, address, and phone number of the manufacturer or importer
- Hazard Labels - Chemical Handlers: hazardous chemicals in the workplace must be labeled in 1 of the following ways:
- Label according to #1 through #5 above.
- Use a label that includes the product identifier and words, pictures, and/or symbols that convey specific physical and health hazard information to the workers
- Safety Data Sheets (SDSs): these documents, which used to be called Material Safety Data Sheets (MSDSs), now have to include specific information and follow a 16-section format
- Employee Information and Training: chemical workers must be trained on the new hazard label and SDS requirements
Now is a good time to review your Hazard Communication/GHS program to ensure that you are complying with the new requirements. Are all your incoming chemicals labeled with pictograms and the other required elements? Are the SDSs that you are receiving following the new required format? Does your in-house hazard labeling system meet the new requirements? Do your employees understand the hazard labels that you and your chemical manufacturer/importer are using? Do you have proof that you trained your employees on these new elements? If you answered "no" to any of these questions, then you have some compliance gaps that need to be addressed.
Cashins & Associates can help you assess your compliance status with this regulation and other OSHA, MassDEP, and EPA regulations. Click on the icon to submit your request for assistance today. We look forward to hearing from you!