Hazard Communication Standard: New Chemical Provisions

Dale Rothenberger has more than 20 years of experience in business transformation and program process management.

How many of you are old enough to remember when OSHA introduced the MSDS and Right to Know programs into the American workplace? This was a disruptive time and quite sizable cost to most businesses to adopt this regulation into their workplace and employee introduction of the program details.

Here we go again…

In June 2012, the United States adopted the same standards as 25 other industrial countries for information regarding the identification of hazardous materials in the workplace. It is a logical and comprehensive approach to:

  • Defining health, physical and environmental hazards of chemicals;
  • Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria; and
  • Communicating hazard information, as well as protective measures, on labels and Safety Data Sheets (SDS).

OSHA is the authority agency for implementation, and requires changes that are incorporated into the Hazard Communication Standard (HCS) and adopted new classification of hazardous materials to fall in line with a universal identification system. These changes are now under way as the HCS aligns with the Globally Harmonized System (GHS) of classification and labeling of chemicals utilized around the world. These revisions are significant and affect all employers who manufacture, distribute, store and use chemicals.

To help companies comply with the revised standard, OSHA is phasing in the specific requirements during the next few years.

Phase 1 is Orientation Training, which must be completed by Dec. 1, 2013.

These regulations affect:

  • Labels—new format for product and transportation;
  • Symbols—pictograms are new and different than what we were taught to recognize; and
  • Employee education—general orientation and familiarization.

It is estimated that more than five million workplaces in the United States will be impacted by the revised HCS. These are all those workplaces where employees—a total of approximately 43 million of them—could be exposed to hazardous chemicals. OSHA anticipates that these changes will make the workplace much safer, because the universal classification and labeling system will make it easier for everyone to understand the proper handling procedures and uses for all chemicals. As a result, trade barriers should be reduced and American businesses that deal with hazardous chemicals should see increased productivity at a higher cost savings.

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