Understanding the Hazard Communication Standard - Technical Article

The Hazard Communication Standard (HCS) is?OSHA's way of ensuring safety to employees who potentially come in contact with hazardous chemicals. Those who manufacture or import chemicals must assess their hazards, as well as create labels and safety data sheets (SDS) that inform their customers of the potential dangers.

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This article concerning OSHA’s revised May 2012 Hazard Communication Standard (HCS)?29 CFR 1910.1200?will center on various new requirements involving chemical manufacturers, importers, distributors and employers regarding universal labeling and classifications of chemicals. Safety Data Sheets (SDS) that have now replaced Material Safety Data Sheets (MSDS) with a globally synchronized format and employee training requirements also will be examined.

This revised OSHA standard is pertinent to processors because of the myriad varieties of potentially?hazardous chemicals?that are used during production, sanitation and maintenance.

OSHA had chosen to align its HCS with the 2009 rev.3?Globally Harmonized System (GHS) to improve the quality and consistency of hazard information while contemporaneously making it safer for workers downstream to perform their jobs.

The GHS is merely a standardized system that’s used worldwide for identifying and properly labeling hazardous chemicals. These standards were created over several years of collaboration between hazard communication experts from across the globe and representatives from OSHA.

OSHA has touted the GHS format as giving workers both domestically and worldwide the “right to understand” the multiple hazards of the chemicals they handle or may come into contact with. These changes will now bring the United States into alignment with the GHS involving the classification and labeling of chemicals both domestically and worldwide. OSHA’s previous HCS standard had allowed chemical manufacturers, importers and distributers to convey hazard information on labels and MSDS in any format they chose.

This new GHS standard will also provide a single set of harmonized standards for classifying chemicals according to their health and physical hazards and specifies clear hazard communication elements regarding labeling.

OSHA implementation dates

Dec. 1, 2013 – Employers must train employees on the new labeling elements and the SDS format.

Jun. 1, 2015 – Chemical manufacturers, importers, distributors and employers must comply with all modified provisions of the final rule. Exception: Distributors could still ship products labeled by manufacturers under the old system until Dec. 1, 2015.

Jun. 1, 2016 – Employers must update alternative workplace labeling and hazard communication program as necessary and provide additional employee training for any newly identified physical or health hazards.

Major changes to the HCS

1. Hazard classifications –?Provides specific and universal standards for the classification of health and physical hazards, including classifications of chemical mixtures.?

2. Labels – Chemical manufacturers, importers and distributors are now required to provide labeling that includes:

• a harmonized signal word;?
• universal pictogram(s);?
• a hazard statement for each hazard class category; and
• applicable precautionary statements. For examples, click?here.

3. Safety Data Sheets (SDS) – Now contains a homogenous 16-section format.

4. Information and training – Employers were required to train their workers by Dec. 1, 2013, on the new labeling elements and the SDS format to facilitate recognition and understanding.

SDS information requirements

The information contained within the SDS is generally identical to the old MSDS format, except now the SDSs are required to be presented in a more consistent and user-friendly 16-section format.

The SDS includes information such as the properties of each chemical; the physical, health and environmental health hazards; protective measures; and the safety precautions for handling, storing and transporting chemicals. The SDS must always be in English, though it may be supplemented in other languages. SDS preparers can also include additional information in various sections, when applicable.

Sections 1 through 8?contain general information about the chemical, identification, hazards, composition, safe handling practices and emergency control measures. This information was intended be helpful for those that need the information in a quick and timely manner.

Sections 9 through 11 and 16?contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision. The SDS must also state that no applicable information was found when the preparer does not find relevant information for any required element.

The SDS also must contain?sections 12 through 15?to be consistent with the United Nations?GHS; however, OSHA will not enforce the content of these sections because they concern subject matters that’s regulated by other governmental agencies.

A brief description of each section of an SDS is provided below:

SECTION 1 – IDENTIFICATION -?This section identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier.

SECTION 2 –?HAZARDS IDENTIFICATION -?This section identifies the hazards of the chemical presented on the SDS and the appropriate warning information associated with those hazards.

SECTION 3 – COMPOSITION/INFORMATION ON INGREDIENTS -?This section identifies the ingredient(s) contained in the product indicated on the SDS, including impurities and stabilizing additives. This section also includes information on substances, mixtures and all chemicals where a trade secret is claimed.

SECTION 4 – FIRST AID MEASURES -?This section describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical.

SECTION 5 – FIRE FIGHTING MEASURES -?This section provides recommendations for fighting a fire caused by the chemical.

SECTION 6 – ACCIDENTAL RELEASE MEASURES -?This section provides recommendations on the appropriate response to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people, properties, or the environment. It may also include recommendations distinguishing between responses for large and small spills where the spill volume has a significant impact on the hazard.

SECTION 7 – HANDLING AND STORAGE -?This section provides guidance on the safe handling practices and conditions for safe storage of chemicals.?

SECTION 8 – EXPOSURE CONTROLS/PERSONAL PROTECTION -?This section indicates the exposure limits, engineering controls, and personal protective measures that’s recommended to be used to minimize worker exposure.

SECTION 9 – PHYSICAL/CHEMICAL PROPERTIES -?This section identifies the physical and chemical properties associated with the substance or mixture.

SECTION 10 – STABILITY AND REACTIVITY -?This section describes the reactivity hazards of the chemical and the chemical stability information. This section is broken into three parts: reactivity, chemical stability, and other(s).

SECTION 11 – TOXICOLOGICAL INFORMATION -?This section identifies toxicological and health effects information or indicates that such data are not available.

SECTION 12 – ECOLOGICAL INFORMATION -?This section provides information to evaluate the environmental impact of the chemical(s) if it were released into the environment.

SECTION 13 – DISPOSABLE CONSIDERATIONS -?This section provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container and safe handling practices. To minimize exposure, this section also should refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS.

SECTION 14 – TRANSPORT INFORMATION -?This section provides guidance on classification information for shipping and transporting of hazardous chemicals by road, air, rail or sea.

SECTION 15 – REGULATORY INFORMATION -?This section identifies the safety, health, and environmental regulations specific for the product that is not indicated anywhere else on the SDS.

The information may also include any national and/or regional regulatory information of the chemical or mixtures, including any OSHA, Department of Transportation, Environmental Protection Agency or Consumer Product Safety Commission regulations.

SECTION 16 – OTHER INFORMATION - This section indicates when the SDS was prepared or when the last known revision were made

Conclusion

OSHA estimates that when this new standard is fully implemented, it will prevent more than 500 workplace injuries and illnesses, including 43 fatalities a year.

Other projected benefits:

• Enhanced worker understanding of chemical hazards, especially for low- and limited-literacy workers;
• reduced confusion in the workplace, facilitate safety training that will result with safer handling and usage of chemicals;
• provides workers quicker and more efficient access to vital information contained within SDSs; and
• provides a projected cost savings to United States businesses of more than $475 million in productivity improvements; and
• fewer SDS and label updates and enhanced hazard communication training.

Steve Sayer - Sayer Consulting / Auditing, LLC