| Q. | Is OSHA going to update the Hazard Communication Standard? |
| A. | Yes, OSHA is planning to modify its existing Hazard Communication Standard (HCS) to conform with the United Nations’ (UN) Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
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| Q. | Why is the standard being changed? |
| A. | OSHA believes the proposed modifications will improve the quality and consistency of information provided to employers and employees regarding chemical hazards and associated protective measures. The improved information is expected to keep employees better apprised of the chemical hazards to which they may be exposed, and reduce the incidence of chemical-related occupational illnesses and injuries.
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| Q. | When will the standard take effect? |
| A. | That isn’t yet known. The updated standard is still in the proposed rule stage. Effective dates will be announced when a final rule is published.
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| Q. | How long will I have to update my Hazard Communication program to ensure compliance with the new rule? |
| A. | Timing in the proposed rule indicates a two year time frame for updating employee training and three years for phasing in full implementation of the new standard.
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| Q. | What is being changed? |
| A. | Proposed modifications include: 1) revised criteria for classification of chemical hazards; 2) revised labeling provisions, including use of standardized signal words, pictograms, hazard statements, and precautionary statements; 3) a specified format for safety data sheets (formerly called material safety data sheets); 4) revisions to definitions of terms; and 5) requirements for updated employee training on labels and safety data sheets.
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| Q. | What is the status of OSHA updating the Hazard Communication Standard (GHS changes)? |
| A. | OSHA’s most recent regulatory agenda showed February, 2012 as the date a new Hazard Communication Standard would be released. That timing appears to be questionable. OSHA sent the new rule to the Office of Management and Budget (OMB) for review in October, 2012. OMB reviews typically have a 90-day deadline; however, that deadline has passed. The OMB web site continues to list the rule as “pending review.” No reason for the delay is provided. We will keep you updated as more information becomes available.
References:
OSHA Regulatory Agenda:
http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201110&RIN=1218-AC20
OMB Hazard Communication Standard Listing:
http://www.reginfo.gov/public/do/eoDetails?rrid=121101
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| Q. | Do changes in the Hazard Communication Standard affect other OSHA standards? |
| A. | Yes, OSHA is planning to modify provisions of a number of other standards, including standards for flammable and combustible liquids, process safety management, and most substance-specific health standards (asbestos, benzene, lead, etc.), to ensure consistency with the modified Hazard Communication Standard requirements.
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| Q. | Do I have to do something new or different to evaluate chemical hazards? |
| A. | Chemical manufacturers or importers will have new responsibilities for evaluating and communicating hazards to employers and employees. Employer responsibilities remain basically the same – effectively communicate the information you receive from your suppliers. “All employers with employees exposed to hazardous chemicals must develop a hazard communication program, and ensure that exposed employees are provided with labels, access to SDSs, and training on the hazardous chemicals in their workplace.”
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| Q. | What will be different about chemical labels? |
| A. | OSHA will be requiring use of standardized signal words (Danger, Warning, Caution, Notice), hazard statements (e.g., Fatal if Swallowed), and pictograms (e.g., skull and crossbones) to communicate hazards.
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| Q. | What will the pictograms look like? |
| A. | You can see examples in “A Guide to The Globally Harmonized System of Classification and Labelling of Chemicals (GHS)” available at: osha.gov. You can also see examples examples.
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| Q. | What will be different about material safety data sheets (MSDS)? |
| A. | The term Safety Data Sheets (SDS) will replace the term MSDS. The purpose will be the same, but a standardized format and consistent terminology will be required. Chemical manufacturers and importers will be required to develop an SDS for each hazardous chemical they produce or import.
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| Q. | Will I have to replace all my MSDS? |
| A. | Yes, eventually you will need to do so. The proposed phase in period is 3 years, but that period has not yet started. The final rule will dictate the timing. OSHA expects old format MSDS and new format SDS to co-exist for some period of time. Their main focus during the transition period will be ensuring that employers continue to have an effective Hazard Communication program in place.
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| Q. | Is an executive summary of proposed changes available? |
| A. | Yes, OSHA has published summaries in many locations (e.g., see the OSHA FAQ)
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| Q. | Where can I find a copy of the proposed rule? |
| A. | Details of the proposed rule can be found here.
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