OSHA’s New Hazard Communication Standard

In March, the Occupational Safety and Health Administration (OSHA) released a revised Hazard Communication Standard that requires employers to train any employees who work with hazardous chemicals to use newly designed hazardous material labels and material safety data sheets (MSDSs).

In pre-K-12 schools, employees who use hazardous chemicals may include science and vocational faculties, school nurses, custodial staff and others depending upon the programs offered by individual schools. Schools offering courses in auto mechanics and agriculture, for instance, may have to train faculty and maintenance staff working with those programs.

OSHA revised the standard to align with the United Nations’ Globally Harmonized System (GHS) of Classification and Labeling of Chemicals, a system being adopted by countries around the world.

“Revising OSHA’s Hazard Communication Standard will improve the quality, consistency and clarity of hazard information that workers receive,” says Secretary of Labor Hilda L. Solis in a written statement announcing the revisions.

What Is Changing?

“The major changes K-12 schools will see will be to labels and safety data sheets, which OSHA now calls SDSs. Also, new training will be required to ensure that employees understand the updated label and SDS formats well enough to find the information they need,” says Brad Harbaugh in the Communications department of MSDSonline, a cloud-based solutions provider that helps organizations comply with environmental, health and safety regulations such as the Hazard Communication Standard.

Schools must complete training of affected teachers and staff by Dec. 1 of this year.

Training for the New Label and MSDS Formats

“In the past, OSHA wasn’t as specific about what had to appear on labels and safety data sheets,” Harbaugh says. “The standard was performance-based, meaning OSHA just told you the effect your labels and MSDSs had to achieve. The revised HazCom standard is prescriptive with OSHA providing specific guidance.”

Training must introduce employees to the two formats. OSHA has prepared a training PDF about this. It begins by defining the six standardized elements of the label.

  • Product identifier: This might be the chemical name, code number or batch number of the chemical. The manufacturer makes the choice. The same product identifier will appear in Section 1 of the product’s SDS.
  • Signal word: Is there a hazard? How severe is it? One of only two signal words will tell you: “Danger” or “Warning.” “Danger” always calls out the more severe hazards.
  • Pictogram: Eight mandatory pictograms and one that is non-mandatory communicate health, physical and environmental hazards on the new labels. All pictograms take the shape of a red diamond sitting on its point. Inside the red diamond, a black hazard symbol rests on a white background. Among the symbols are a flame, gas cylinder, exploding bomb and skull-and-crossbones. Each pictogram indicates between one and a half dozen specific hazards.
  • Hazard statement(s): All applicable hazard statements must appear on the label. They may be combined to save space and improve readability. The statements will describe the nature and degree of the hazards.
  • Precautionary statement(s): This area of the label describes measures that will minimize or prevent adverse effects from exposure to a hazardous chemical or improper storage or handling.
  • Supplier Information: The name, address and phone number of the manufacturer, distributor, importer or responsible party must also appear on the label.

Using the Labels

Training must also guide employees in the use of the label. Point out, for example how label information ensures proper storage or provides a quick source of first aid information. Employees should understand how the label elements correspond to information found on the SDS in sections 1 and 2.

OSHA also recommends going over the various pictograms and the hazards they identify.

Safety Data Sheet Training

The new SDS format will contain much of the same information as found on existing SDSs, but it will be organized differently into these 16 sections in the following order.

  1. Identification
  2. Hazard(s) identification
  3. Composition/information on ingredients
  4. First-aid measures
  5. Fire-fighting measures
  6. Accidental release measures
  7. Handling and storage
  8. Exposure controls/personal protection
  9. Physical and chemical properties
  10. Stability and reactivity
  11. Toxicological information
  12. Ecological information
  13. Disposal considerations
  14. Transport information
  15. Regulatory information
  16. Other information, including date of preparation or last revision

Training should introduce employees to the kinds of information to be found in each of the 16 sections, while pointing out sections that contain the same information as the label.

Making the Transition

As you prepare to train employees about the new standard, Harbaugh recommends several additional steps.

These include designating a GHS transition leader, inventorying chemicals and updating your SDS library. You should also track new labels and SDSs that arrive and develop a GHS compliant secondary container labeling strategy.

For instance, OSHA gives you secondary labeling options. “You can replicate the information on the shipping label, use some combination of the six label elements, or use an alternative labeling system,” Harbaugh says. “Whatever you choose to do, your workplace labels must provide employees with the same quality of information as they would receive from a manufacturer label on a shipped container.” 

The final deadline for full compliance is June 1, 2016. Harbaugh recommends completing a number of tasks over the next three years. You will need to complete a library of new SDSs, while archiving older ones. You must train employees to deal with any new hazards noted on the SDSs. Your will have to relabel secondary containers in the GHS format. You may also have SARA/EPCRA reporting obligations.

Finally, you will have to update your written Hazardous Communication Plan.

It’s a lot of organizational and training work, but OSHA estimates that the new standard will prevent 43 deaths and 585 injuries and illnesses, while enhancing productivity by $475.2 million annually. Which will make it worthwhile.