The 2012 changes to the Hazard Communication Standard (HCS) of the Occupational Safety and Health Administration brought the United States into alignment with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

According to the final rule, the GHS/HCS compliance requirements will be phased in over a four-year period.  The first compliance date, which is quickly approaching, requires employers to deliver new hazard communication training to their employees. The following is an overview of the GHS/HCS training requirements outlined by OSHA so employers can have a better understanding of their responsibilities.
<h3><b>HazCom Training</b></h3>
Generally, an employer covered by the HCS must demonstrate that they meet the specific training requirements found in 29 CFR § 1910.1200 (h). This training requirement applies to all employers that use, handle and store chemicals.

The deadline to complete the initial employee training is <b>December 1, 2013</b>. Employees must receive training about the new chemical labels and safety data sheets (SDS), which were previously referred to as material safety data sheets, or MSDSs. New information and/or handling recommendations may exist for chemicals that have been in use for many years.
<h3><b>OSHA’s Required “Minimum” Training Elements</b></h3>
OSHA specifies that, at a minimum, an employer hazcom training program will include instruction on the elements of GHS/HCS labels¹.  These elements include:
<ul>
<li>Product identifier;</li>
<li>Signal word;</li>
<li>Hazard statement(s);</li>
<li>Precautionary statement(s); and</li>
<li>The contact information (name; address; phone number) of the chemical manufacturer, distributor, or importer.</li>
</ul>
Furthermore, OSHA states that the hazcom training will cover the manner in which GHS/HCS labels are used in the workplace and how chemical hazard safety information will appear on incoming chemical shipments. Additional training will include coverage of the newly required SDS 16-section format and the information found in each section.
<h3><b>Written Hazcom Programs</b></h3>
The HCS mandates that the employer must maintain a written hazard communication program that provides an explanation of the specific aspects of employee hazcom training.  Such a description should include an outline of the course content along with the methodology used to deliver the training. Suggested training topics include:
<ul>
<li>Chemical specific training;</li>
<li>General chemical safety training;</li>
<li>Safety measures taken when handling workplace chemicals;</li>
<li>Incident and first-aid instruction;</li>
<li>Non-routine tasks;</li>
<li>Contractor safety; and</li>
<li>Chemical pipe safety (if applicable).</li>
</ul>
<h3><b>Background</b></h3>
The HCS was enacted to help ensure that chemical hazard information is dispersed to downstream users.  To do this, the HCS requires chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import, and to provide chemical safety information through labels on shipped containers and more detailed information on safety data sheets (SDSs). Covered employers (those with hazardous chemicals being used in their workplaces) are required to prepare and implement a written hazard communication program, ensure that all containers are labeled and provide employees with access to SDSs.  An effective training program must be in place to educate all employees with a risk of potential exposure.

The HCS provides workers with the “right-to-know” about the hazards and identities of the chemicals they are or may be potentially exposed to in their place of employment. Compliance with the HCS helps employers maintain safer workplaces for their employees. When employees have information about the hazardous chemicals they are working with, they can take important steps to reduce chemical exposure. These efforts will help prevent the occurrence of work-related chemical source illnesses and injuries.
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With the December 2013 GHS training deadline approaching quickly, companies should begin planning their GHS training sessions immediately. Labelmaster offers <a title=”GHS Training Kits and Labels” href=”http://www.labelmaster.com/GHS” target=”_blank”>a variety of GHS-related products</a> to help companies begin their transition to the revised hazcom standard, including <a title=”GHS Training Programs and Manuals” href=”http://www.labelmaster.com/shop/safety/ghs-hazcom-products/ghs-training-program-and-manuals” target=”_blank”>training programs and manuals</a>, <a title=”GHS and SDS Training Cards and Posters” href=”http://www.labelmaster.com/shop/safety/ghs-hazcom-products/ghs-and-sds-training-cards-and-posters” target=”_blank”>training cards and posters</a>, and <a title=”GHS Pictogram Labels” href=”http://www.labelmaster.com/shop/safety/ghs-hazcom-products/ghs-pictogram-labels” target=”_blank”>pictogram labels</a>. Please <a title=”Contact Labelmaster” href=”http://www.labelmaster.com/contactus/scripts/contact_us_main.cfm” target=”_blank”>contact us</a> for more information on any these products.
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1. OSHA Fact Sheet, DSG FS-3642 02/2013

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