OSHA has adopted new hazardous chemical labeling requirements as a part of its recent revision of the Hazard Communication Standard, 29 CFR 1910.1200 (HCS), bringing it into alignment with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This is getting to be old news but as the deadline approaches most companies have yet to complete the required training.
The revised HCS changes the existing Hazard Communication Standard (HazCom 1941) from a performance-based standard to one that has more structured requirements for the labeling of chemicals. The revised standard requires that information about chemical hazards be conveyed on labels using quick visual notations to alert the user, providing immediate recognition of the hazards. Labels must also provide instructions on how to handle the chemical so that chemical users are informed about how to protect themselves. Safety Data Sheets (SDSs), which must accompany hazardous chemicals, are the more complete resource for details regarding hazardous chemicals. The revised standard also requires the use of a 16-section safety data sheet format.
The HCS requires chemical manufacturers, importers, or distributors to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following information: product identifier; signal word; hazard statement(s); precautionary statement(s); and pictogram(s); and name, address and telephone number of the chemical manufacturer, importer, or other responsible party.
NOTE: This is a requirement of the “chemical manufacturers, importers, or distributors” not the employer.
OSHA has not changed the general requirements for workplace labeling. If an employer has an in-plant or workplace system of labeling that meets the requirements of HazCom 1994, the employer may continue to use this system in the workplace as long as this system, in conjunction with other information immediately available to the employees, provides the employees with the information on all of the health and physical hazards of the hazardous chemical.
Employers may continue to use rating systems such as National Fire Protection Association (NFPA) diamonds or HMIS requirements for workplace labels as long as they are consistent with the requirements of the Hazard Communication Standard and the employees have immediate access to the specific hazard.
Employers are responsible for maintaining the labels on the containers, including, but not limited to, tanks, totes, and drums. This means that labels must be maintained on chemicals in a manner which continues to be legible and the pertinent information does not get defaced or removed in any way. The employer must relabel items if the labels are removed or defaced.
Required Training (by 12/1/13)
By December 1, 2013 employers must have trained their workers on the new label elements and the SDS format. This training needs to include the following:
- Training on labeling requirements;
- Product Identifier
- Signal Word
- Hazard Statement
- Precautionary Statement
- General training on how to read and understand labeling information
- Training on the format of the SDS and how to determine chemical hazards.
Please contact Jim Charles if you need support updating your existing training program. We can prepared the training program and train your staff on the new requirements.