In a press release yesterday, the U.S. Department of Labor (DOL) announced that OSHA has revised its Hazard Communication Standard §1910.1200 to align with the United Nations’ Globally Harmonized System (GHS). The Final Rule will be published in the Federal Register on March 26, 2012 and becomes effective 60 days after publication.
OSHA has updated its Hazard Communication page with a wealth of information about the revised requirements, designed to provide consistency in chemical hazard identification. Here’s a quick summary of some highlights.
Chemical labeling
Employers must now use chemical labels as specified under the revised rule or approved alternatives. On their questions and answers page, OSHA clarifies that acceptable alternatives include the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) as long as these formats present no conflicting information (e.g., hazard warnings or pictograms).
OSHA provides a sample label to show what information compliant labels must contain – the same key components identified in the UN’s document.
- Pictograms
- Signal word
- Hazard & precautionary statements
- Product identifier
- Supplier identification
Safety Data Sheets
Under the revised Hazard Communication Standard, Safety Data Sheets (SDS) - no longer called Manufacturer Safety Data Sheets (MSDS) - will follow the ANSI standard 16-section format. Important to note is that OSHA will not mandate Sections 12-15 since other agencies regulate this information.
Pictograms
OSHA has created a Quick Card™ to identify the nine pictograms and outline what hazards each represents. The Environment pictogram is considered non-mandatory since environmental hazards fall outside OSHA’s jurisdiction.
All pictograms must have a red border - no exceptions.
It’s time to get busy
The Final Rule becomes effective 60 days after publication. OSHA's Fact Sheet outlines what that means for compliance dates. I've reframed that information (shown below) to answer the big Who, What, and When.
|
Who |
What |
When |
|
Employers |
Train employees on the new label elements and SDS format. |
By Dec 2013 |
|
Chemical manufacturers, importers, distributors & employers |
Comply with all modified provisions of the final rule with the exception that distributors may ship products labeled by manufacturers under the old system until December 1, 2015. |
By June 2015 |
|
Employers |
Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. |
By June 2016 |
|
All chemical manufacturers, importers, distributors and employers |
During the transition period, there must be compliance with either 29 CFR 1910.1200 (the final standard), or the current standard, or both. |
Transition period |
Stay tuned for more on GHS in the coming weeks. For available GHS solutions from Accuform Signs, visit our GHS product page.
The information provided is for general purposes only, and not to be relied upon as legal advice, legal opinion, and absolute and complete for the specific facts or circumstances.
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