In an effort to “improve the quality and consistency of hazard information, making it safer for workers to do their jobs and easier for employers to stay competitive,” the Occupational Safety & Health Administration (OSHA) has revised its Hazard Communication Standard to align it with the Globally Harmonized System of Classification and Labeling of Chemicals, also known as GHS.
As revealed during a teleconference this morning, the final rule implementing this new hazcom standard will be published on March 26, 2012, although the text of OSHA’s GHS final rule is now available for public inspection. According to OSHA’s new Web site devoted to the revised hazcom standard, the update will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets:
“Once implemented, the revised standard will improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals. This update will also help reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store, and use hazardous chemicals while providing cost savings for American businesses that periodically update safety data sheets and labels for chemicals covered under the hazard communication standard.”
During her teleconference remarks, U.S. Secretary of Labor Hilda Solis said that an estimated 43 million workers are covered by the hazcom system. The revised system is estimated to prevent more than 500 injuries, save 43 lives and result in $475.2 million in productivity improvements, according to Solis.
Dr. David Michaels, the U.S. Assistant Secretary of Labor for Occupational Safety and Health, noted that the new standard is being touted as “the right to understand,” a revision of the “right to know” concept that accompanied the original hazcom standard.
The OSHA hazcom standard Web site provides a wealth of important information related to the new regulations, including a sample hazard communication standard label and an FAQ. The following is important information as it relates to labeling requirements for the transition to GHS:
Changes to Hazcom Labels
According to OSHA, under the current Hazard Communication Standard (HCS), the label preparer must provide the identity of the chemical, and the appropriate hazard warnings. This may be done in a variety of ways, and the method to convey the information is left to the preparer. Under the revised HCS, once the hazard classification is completed, the standard specifies what information is to be provided for each hazard class and category. Labels will require the following elements:
- Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the HCS.
- Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for less severe hazards.
- Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
- Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical.
OSHA has provided an example hazard communication standard label for reference.
GHS Hazard Pictograms
OSHA notes that there are nine pictograms under the GHS to convey the health, physical and environmental hazards. The final hazcom standard requires eight of these pictograms, the exception being the environmental pictogram, as environmental hazards are not within OSHA’s jurisdiction. The hazard pictograms and their corresponding hazards are:
- Reproductive Toxicity
- Respiratory Sensitizer
- Target Organ Toxicity
- Aspiration Toxicity
- Emits Flammable Gas
- Organic Peroxides
- Irritant (skin and eye)
- Skin Sensitizer
- Acute Toxicity (harmful)
- Narcotic Effects
- Respiratory Tract Irritant
- Hazardous to Ozone Layer (Non Mandatory)
- Gases under Pressure
- Skin Corrosion/ burns
- Eye Damage
- Corrosive to Metals
- Organic Peroxides
Flame over Circle
Environment (Non Mandatory)
- Aquatic Toxicity
Skull and Crossbones
- Acute Toxicity (fatal or toxic)
Borders on HazCom Labels
OSHA mentions that under the revised hazcom standard, pictograms must have red borders. OSHA believes that the use of the red frame will increase recognition and comprehensibility. Therefore, the red frame is required regardless of whether the shipment is domestic or international.
In addition, OSHA is lifting the stay on enforcement regarding the provision to update labels when new information on hazards becomes available. Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information. If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.
Revised Workplace HazCom Labeling Rules
OSHA states that the current standard provides employers with flexibility regarding the type of system to be used in their workplaces and that flexibility has been retained in the revised hazcom standard. Employers may choose 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. Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent with the revised hazcom standard, e.g., no conflicting hazard warnings or pictograms.
OSHA notes that it initially proposed to include hazards currently covered under the hazcom standard that have yet to be addressed by the GHS in a separate category called “Unclassified Hazards.” In response to comments from the regulated community, OSHA has renamed the category to “Hazards Not Otherwise Classified (HNOC)” to minimize confusion. In the final hazcom standard, HNOC hazards will not be required to be disclosed on the label but will be required to be disclosed in section 2 of the Safety Data Sheet (SDS). This reflects how GHS recommends these hazards should be disclosed. Chemical manufacturers and importers are expected to assess these hazards when they are conducting their hazard evaluation of physical and health hazards. A new or separate evaluation is not required.
Effective Dates for Revised Hazard Communication Standard
- December 1, 2013 – Employers must train employees on the new label elements and safety data sheet (SDS) format.
- June 1, 2015 – Chemical manufacturers, importers, distributors and employers must comply with all modified provisions of the final rule. One exception to this date is that distributors have until Dec. 1, 2015, to begin shipping containers labeled by the chemical manufacturer or importer with a GHS label.
- June 1, 2016 – Employers must update alternative workplace labeling and hazard communication programs as necessary, and provide additional employee training for newly identified physical or health hazards.
- Transition Period – Chemical manufacturers, importers, distributors, and employers will have a transition period to the effective completion dates. During this time, they may comply with either 29 CFR 1910.1200 (the final hazcom standard), or the current hazcom standard, or both.
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To help companies begin their transition to this revised hazcom standard, Labelmaster offers a variety of GHS products, including GHS pictogram labels and the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals. In addition, we will be updating our line of hazard communication labels in sync with the changes specified by the transition to GHS alignment. We will provide more information on these new labels in the months to come.
If you have any questions about the revised hazcom standard or GHS, please don’t hesitate to contact our regulations department at 800-621-5808.