The National Fire Protection Association (NFPA) and the Occupational Safety and Health Administration (OSHA) have collaborated to provide guidance on workplace labeling in light of the changes brought by OSHA’s alignment with the United Nation’s GHS labeling protocol. The result of the collaboration is the release of a new NFPA/OSHA Quick Card, which is designed to illustrate differences between NFPA 704 and HazCom/GHS 2012 labels. Download your copy here: http://www.nfpa.org/Assets/files/AboutTheCodes/704/NFPA704_HC2012_QCard.pdf
Along similar lines, on July 25th of this year the Society for Chemical Hazard Communication (SCHC) conducted an internet webinar clarifying certain provisional requirements of the new HCS. The webinar, presented via “Alliance: an OSHA Cooperative Program”, focused on the looming deadline for initial employer training requirements (safety data sheet and HCS/GHS labeling elements). The webinar also pointed out key differences between NFPA 704 and HCS/GHS 2012 label appearance and intended use. The webinar may be viewed here: https://citrix.webcasts.com/viewer/event.jsp?ei=1009539
Workplace (in-house) Labeling Systems
OSHA understands that many employers use their own styles/methods/systems to effectively convey chemical hazard communication to employees. The agency has granted flexibility in the current standard to account for employers using established hazard communication systems as long as their systems are updated to meet the requirements of the HCS 2012. Employers may continue to use any type of chemical hazard information labeling system in their workplace. Specifically, employers may opt to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard.
NFPA Numerical Rating & HazCom 2012 Hazard Class Categorization
The revised regulation precludes sole use of the NFPA 704 label as a stand-alone HazCom labeling system. When describing components of the HCS/GHS, note that the greater the chemical hazard severity, the lower the hazard number; while NFPA 704 labeling criteria indicates the greater the severity, the higher the chemical hazard number. At first pass, this would seem to be a contradiction, but there is more to this equation.
Workplace chemical hazard information labels compliant with HazCom 2012 will adequately inform workers about the hazards of chemicals in the workplace under normal conditions of use and foreseeable emergencies. Such hazards in the workplace may include acute and chronic exposure or potential exposure to employees. Although it may initially be conceived as a potent and immediate confusion factor for workers, in HCS/GHS, the categorization data are not employed or visible on the container label. Categorization numerical data are only present on the safety data sheet. The new HCS of 2012 requires employers to train employees to understand the contents/data found in each section of a safety data sheet (SDS). This training will include understanding the HCS/GHS hazard class and category numbering.
NFPA 704 is intended to provide the basic information for emergency response personnel responding to a fire or spill and those planning for emergency response. In other words, an NFPA 704 placard or label will offer acute chemical hazard information presented numerically for immediate recognition. As described by the National Fire Protection Association (NFPA), “The system is characterized by the “diamond shape” that is actually a “square-on-point” shape. It identifies the hazards of a material and the degree of severity of the health, flammability, and instability hazards. Hazard severity is indicated by a numerical rating that ranges from zero (0) indicating a minimal hazard, to four (4) indicating a severe hazard. Many employers utilize NFPA 704 labels as a workplace chemical hazard information system and have historically deemed 704 a useful compliance tool. However, make no mistake; only using NFPA 704 labels in the workplace is not enough to comply with HazCom 2012, nor is it the intended purpose of this system.
Headquartered in Quincy, Massachusetts, the NFPA’s stated mission is to circulate fire safety codes and standards intended to minimize the possibility and effects of fire and other risks. For more information on the NFPA, visit: http://www.nfpa.org/about-nfpa/overview
