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  Frequently Asked Questions about GHS

OSHA has announced that the final version of the new Hazard Communication Standard (HCS) will be published in the Federal Register on Monday, March 26, 2012.  A Pre-publication version of the document is available here. The deadline of most importance is likely to be employee training.  For that, the “Agency has determined that covered employers must complete all training regarding the new label elements and SDS format by December 1, 2013.”

We will be publishing more details here and communicating with each of our clients via phone and email after the standard is officially printed in the Federal Register.

Q.Has OSHA updated the Hazard Communication Standard?
A.Yes. An updated Hazard Communication Standard was published in the Federal Register on March 26, 2012 (http://www.osha.gov/dsg/hazcom/ghs-final-rule.html).

Q.Why was the standard changed?
A.The standard was modified so U.S. requirements would more closely conform with those of the United Nations’ (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS).OSHA believes the 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.

Q.When will the standard take effect?
A.The new standard includes a series of compliance deadlines (http://www.osha.gov/dsg/hazcom/HCSFactsheet.html). By December 1, 2013, employees must be trained on new label elements included in the standard, as well as trained on the new Safety Data Sheet (SDS) format. By June 1, 2015, compliance with all other aspects of the new rule is required, with one exception for distributors. They may ship product labeled under the old standard until December 31, 2015. By June 1, 2016, alternative workplace labeling and hazard communication programs must be updated as necessary, and employees provided with additional training for newly identified physical or health hazards.

Q.How long will I have to update my Hazard Communication program to ensure compliance with the new rule?
A.Employers must be in full compliance with the new standard by June 1, 2015. Between now and June 1, 2015 (transition period), employers may comply with either the new standard or the previous standard. If an employer receives products labeled under the old standard between June 1 and December 31, 2015 due to the labeling exception allowed for distributors, and secondary deadline of June 1, 2016 will apply to any additional hazard communication program updates needed to be in full compliance with the new requirements.

Q.What has changed?
A.The revised Hazard Communication Standard (HCS) is a modification to the existing standard. The parts of the standard that did not relate to the GHS (such as the basic framework, scope, and exemptions) remained largely unchanged. There have been some modifications to terminology in order to align the revised HCS with language used in the GHS. For example, the term "hazard determination" has been changed to "hazard classification" and "material safety data sheet" was changed to "safety data sheet." Major changes include: 1) Hazard classification: specific criteria for classification of health and physical hazards, as well as for classification of mixtures, are included in the new standard. 2) Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. 3) Safety Data Sheets: a specified 16-section format. 4) Information and training: Annual training continues to be required and employers may continue to rely on a hazard communication program compliant with the old standard until June 1, 2015; however, employers are required to train workers by December 1, 2013 on the new labels elements and safety data sheet format to facilitate recognition and understanding as this information becomes available. A side-by-side comparison of the new standard versus the old standard is available at http://www.osha.gov/dsg/hazcom/side-by-side.html

Q.Do changes in the Hazard Communication Standard affect other OSHA standards?
A.Yes, OSHA modified 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.

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.”

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.

Q.What will the pictograms look like?
A.Pictograms are available on the OSHA web site. Go to http://www.osha.gov/Publications/HazComm_QuickCard_Pictogram.html.

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.

Q.Will I have to replace all my MSDS?
A.Yes, you will need to do so during the transition period to the new standard. Your MSDS files must be updated with appropriate SDS files by June 1, 2015. 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.

Q.Is an executive summary of changes available?
A.Yes, OSHA has published summaries in many locations (e.g., see http://www.osha.gov/dsg/hazcom/index.html)

Q.Where can I find a copy of the new rule?
A.Details of the rule can be found at http://www.osha.gov/dsg/hazcom/ghs-final-rule.html.


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