In the United States of America, GHS is changing only a few things on how we look at chemicals and Chemical Safety. The new HCS still requires chemical manufacturers and importers to classify the chemicals they produce or import and provide hazard information to employers and workers by putting labels on containers and preparing Safety Data Sheets or SDSs (formerly known as Material Safety Data Sheets or MSDSs).
However, the old standard allowed chemical
manufacturers and importers to convey hazard information on labels and
Material Safety Data Sheets in whatever format they chose. The modified
standard provides a single set of harmonized criteria for classifying
chemicals according to their health and physical hazards, and specifies
hazard communication elements.
Major Changes
Definitions: In order to be consistent with GHS, the majority of existing
definitions were modified and/or deleted and replaced with new definitions.
Classification: Chemical manufacturers and importers are required to
determine the hazards of the chemicals they produce or import. Hazard
classification under the new, updated standard provides specific criteria to
address health and physical hazards, as well as classification of chemical
mixtures.
Written Program: OSHA is maintaining the provisions of this section with no
significant changes. GHS does not include any requirements regarding a
written program. However, existing written programs will need to be
modified to reflect new terminology (like SDSs), definition changes and
labeling.
Labels: Chemical manufacturers and importers must provide a label that
includes a signal word, pictogram, hazard statement, product identifier,
supplier identification and precautionary statement for each hazard class
and category.
Safety Data Sheets: The new format requires 16 specific sections to ensure
consistent presentation of important protection information.
Information and Training: To facilitate understanding of the new system, the
new standard requires that workers be trained by December 1, 2013, on the
new label elements and SDS format, in addition to the current training
requirements.
Benefits of the New Standard
The new standard covers over 43 million workers who produce or handle
hazardous chemicals in more than five million workplaces across the
country. The modification is expected to prevent more than 500 workplace
injuries and illnesses and 43 fatalities. Once fully implemented, the standard
will also:
Improve the quality and consistency of hazard information in the workplace,
making it safer for workers to do their jobs and easier for employers to stay
competitive.
Enhance worker comprehension of hazards, especially for low and limited-
literacy workers, reduce confusion in the workplace, facilitate safety training
and result in safer handling and use of chemicals.
Provide workers quicker and more efficient access to information on the
SDSs.
Result in cost savings to American businesses of more than $500 million in
productivity improvements, fewer SDS and label updates and simpler new
hazard communication training.
Reduce trade barriers by harmonizing with systems around the world.
What You Need to Do and When
Chemical Producers (Category 1):
Review hazard information for all chemicals produced or imported, classify
chemicals according to the new classification criteria and update labels and
SDSs by June 1, 2015.
Chemical Users (Category 2): Continue to update SDSs when new ones
become available, provide training on the new label SDS elements by
December 1, 2013, update hazard communication programs if new hazards
are identified and update workplace labels to new GHS criteria by June 1,
2016.
Labels & Programs
OSHA has updated the requirements for labeling of hazardous chemicals
under its HCS.
As of June 1, 2015, all labels from manufacturers will be required to meet the
GHS label format. This will mostly apply to chemical manufacturers.
Workplace labels meeting GHS criteria must be in place as of June 1, 2016.
What does the new GHS label look like and require?
It will require 6 items: product identifier, supplier identification,
precautionary statement, pictogram, hazard statement and signal word.
Employers will simply transfer this information to workplace labeling.
OSHA will continue to allow employers to use other workplace labeling
systems, but the information supplied on these labels must be consistent
with the revised labeling of the GHS system, resulting in a hybrid label of
both systems. This will require a very strong understanding of the
classification system of the GHS system. Both the NFR and HMIG use
numerical rating scales of 0 to 4 (0 being no hazard and 4 being the worst).
GHS hazard categories are just the opposite. Without a firm understanding of
GHS classification, this may introduce further inconsistency of label types if
not done right.
Label Programs
As of June 1, 2015 the HCS will require chemical manufacturers to use
pictograms on labels to alert users of the chemical hazards to which they
may be exposed. Each pictogram consists of a symbol on a white
background framed within a red border and represents a distinct hazard(s).
The pictogram on the label is determined by the chemical hazard
classification.
Health Hazard
Carcinogen
Mutagenicity
Reproductive Toxicity
Respiratory Sensitizer
Target Organ Toxicity
Aspiration Toxicity
Flame
Flammables
Pyrophorics
Self-Heating
Emits Flammable Gas
Self-Reactives
Organic Peroxides
Exclamation Mark
Irritant (skin and eye)
Skin Sensitizer
Acute Toxicity
Narcotic Effects
Respiratory Tract Irritant
Hazardous to Ozone Layer
(Non-Mandatory)
Gas Cylinder
Gases Under
Pressure
Corrosion
Skin Corrosion/Burns
Eye Damage
Corrosive to Metals
Exploding Bomb
Explosives
Self-Reactives
Organic Peroxides
Flame Over Circle
Oxidizers
Environment
(non-Mandatory)
Aquatic Toxicity
Skull and Crossbones
Acute Toxicity
(fatal or toxic)
Safety Data Sheets
The HCS requires chemical manufacturers, distributors or importers to
provide SDSs to communicate the hazards of hazardous chemical products.
As of June 1, 2015, the GHS will require new SDSs to be in a uniform format,
including the section numbers, headings and associated information.
Sections include:
1. Identification includes product identifier; manufacturer or distributor
name, address, phone number; emergency phone number;
recommended use; restrictions on use.
2. Hazard(s) Identification includes all hazards regarding the chemical;
required label elements.
3. Composition/Information on Ingredients includes information on
chemical ingredients; trade secret claims.
4. First-Aid Measures include important symptoms/effects,acute, delayed;
required treatment.
5. Fire-Fighting Measures list suitable extinguishing techniques,
equipment; chemical hazards from fire.
6. Accidental Release Measures list emergency procedures; protective
equipment; proper methods of containment and cleanup.
7. Handling and Storage list precautions for safe handling and storage,
including incompatibilities.
8. Exposure Controls/Personal Protection list OSHA’s Permissible
Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate
engineering controls; personal protective equipment (PPE).
9. Physical and Chemical Properties list the chemical’s characteristics.
Stability and Reactivity list chemical stability and possibility of
hazardous reactions.
10. Toxicological Information includes routes of exposure; related
symptoms, acute and chronic effects; numerical measures of toxicity.
11. Ecological Information* provides information to evaluate the
environmental impact of the chemical(s) if it were released to the
environment.
12. Disposal Considerations* provide guidance on proper disposal
practices, recycling or reclamation of the chemical(s) or its container
and safe handling practices. Will most likely refer reader to section 8
to minimize exposure.
13. Transport Information* provides guidance on classification
information for shipping and transporting of hazardous chemical(s) by
road, air, rail or sea.
14. Regulatory Information* identifies the safety, health and
environmental regulations specific for the product that is not indicated
anywhere else on the SDS.
15. Other Information includes the date of preparation or last
revision.
*Note: Since other Agencies regulate this information, OSHA will not be
enforcing sections 12 through 15 (29 CFR 1910.1200(g)(2)). This information
must be provided to meet GHS requirements for SDSs.
Other OSHA Rules Affected
Flammable and Combustible Liquids 29 CFR 1910.106
This will amend flammable and combustible liquids to conform to new
flammability classes based on new flashpoint methods and boiling points
consistent with the GHS criteria. The biggest change will be the
classification of flammable and combustible liquids. The term “combustible”
will be eliminated and replaced with just “flammable”. The new GHS
definition of flammable aerosols should also be incorporated into this
standard and updated with the acceptable methods for determining
flashpoints.
Process Safety Management (PSM) 29 CFR 1910.119 and Hazwoper 29 CFR
1910.120
Incorporate new flammable liquid classes for consistency.
Welding 29 CFR 1910.252
Incorporate new label format on welding consumables for consistency.
Substance-Specific Health Standards 29 CFR 1910.1001– 1910.1450
(Asbestos, Lead, Cadmium, etc.) Most of the changes made are editorial to
be consistent with new labeling and SDS terminology. The wording on the
signage required in these standards, particularly cancer-causing chemicals
(which almost all of these are), will be modified to reflect standardized
wording required under the GHS criteria.
One of the most significant changes in the revised standard is the adoption
of the United Nations' Globally Harmonized System of Classification and
Labeling of Chemicals (GHS). This adoption provides a single set of
harmonized criteria for classifying chemicals according to their health and
physical hazards. The information required on the Safety Data Sheet (SDS),
formerly referred to as a Material Safety Data Sheet (MSDS), has remained
essentially the same. However, the revision requires the information on the
SDS be presented using 16 specific headings in a specified sequence. 29 CFR
1910.1200(g) provides the heading information to be included and the order
in which they are to be provided. 29 CFR 1910.1200 Appendix D provides the
information to be included under each heading. The SDS format is the same
as the American National Standards Institute Z400.1/Z129.1-2010 Hazardous
Workplace Chemicals – Hazard Evaluation and Safety Data Sheet and
Precautionary Labeling Preparation Standard format that is widely used in
the U.S. and is already familiar to many.
Sections 1 through 8 of the SDS contain general information about the
chemical, identification, hazards, composition, safe handling practices and
emergency control measures. 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. To be consistent with GHS, the SDS must also
contain Sections 12 through 15: ecological information, disposal
considerations, transport information and other regulatory information. OSHA
does not enforce the content of these sections because they fall outside of
its jurisdiction. A description of all 16 sections of the SDS, along with their
contents, is given below:
Section 1: Identification
Identifies the chemical and the recommended uses. It also provides the
supplier’s essential contact information. Required information consists of:
• Product identifier used on the label and any other common names or
synonyms by which the substance is known
• Name, address, phone number of the manufacturer, importer or other
responsible party, and emergency phone number
• Recommended use of the chemical; a brief description of what it
actually does and any restrictions on use
Section 2: Hazard(s) Identification
Identifies the hazards of the chemical and the appropriate warning
information associated with those hazards. Required information consists of:
• Hazard classification of the chemical
• Signal word
• Hazard statement(s)
• Pictograms
• Precautionary statement(s)
• Description of any hazards not otherwise classified
• For a mixture that contains an ingredient(s) with unknown toxicity, a
statement describing how much (percentage) of the mixture consists
of ingredient(s) with unknown acute toxicity. This is a total
percentage of the mixture and not tied to the individual ingredient(s).
Section 3: Composition/Information on Ingredients
Identifies the ingredient(s) contained in the product, including impurities and
stabilizing additives. This section includes information on substances,
mixtures and all chemicals where a trade secret is claimed. Required
information consists of:
• Substances
o Chemical name
o Common name and synonyms
o Chemical Abstracts Service (CAS) number and other unique
identifiers
o Impurities and stabilizing additives, which are themselves
classified and contribute to the classification of the chemical
• Mixtures
o Same information required for substances
o The chemical name and exact percentage of all ingredients
that are classified as health hazards and are:
� Present above their cut-off/concentration limits or
� Present a health risk below the cut-off/concentration
limits
� The exact percentages of each ingredient must be
specified except concentration ranges may be used
in the following situations:
• - A trade secret claim is made
• - There is batch-to-batch variation
• - The SDS is used for a group of substantially
similar mixtures
• Chemicals where a trade secret is claimed
o A statement that the specific chemical identity and/or exact
percentage (concentration) of composition has been withheld
as a trade secret is required
Section 4: First Aid Measures
Describes the initial care that should be given by responders to an individual
who has been exposed to the chemical. Required information consists of:
• Necessary first aid instructions relevant to the route(s) of exposure:
inhalation, skin and eye contact, and ingestion
• Description of the most important symptoms or effects, and any
symptoms that are acute or delayed
• Recommendations for immediate medical care and special treatment
needed, when necessary
Section 5: Fire-Fighting Measures
Provides recommendations for fighting a fire caused by the chemical.
Required information consists of:
• Recommendations of suitable extinguishing equipment
• Information about extinguishing equipment that is not appropriate for a
particular situation
• Advice on specific hazards that develop from the chemical during the
fire; any hazardous combustion products created when the chemical
burns
• Recommendations on special protective equipment or precautions for
firefighters
Section 6: Accidental Release Measures
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.
Required information may consist of recommendations for:
• Use of precautions and protective equipment to prevent the
contamination of skin, eyes and clothing
• Emergency procedures, including instructions for evacuations,
consulting experts when needed, and appropriate protective clothing
• Methods and materials used for containment
• Cleanup procedures/techniques
Section 7: Handling and Storage
Provides guidance on the safe handling practices and conditions for safe
storage of chemicals. Required information consists of:
• Precautions for safe handling, including recommendations for handling
incompatible chemicals, minimizing the release of the chemical into
the environment and providing advice on general hygiene practices
• Recommendations on the conditions for safe storage, including any
incompatibilities
Section 8: Exposure Controls/Personal Protection
Indicates the exposure limits, engineering controls and personal protective
measures that can be used to minimize worker exposure. Required
information consists of:
• OSHA Permissible Exposure Limits (PELs), American Conference of
Governmental Industrial Hygienists (ACGIH) Threshold Limit Values
(TLVs) and any other exposure limit used or recommended by the
chemical manufacturer, importer or employer preparing the safety
data sheet, where available
• Appropriate engineering controls
• Recommendations for personal protective measures to prevent illness
or injury from exposure to chemicals, such as personal protective
equipment (PPE) and any special requirements for the PPE
Section 9: Physical and Chemical Properties
Identifies physical and chemical properties associated with the substance or
mixture. Minimum required information consists of:
• Appearance (physical state, color, etc.)
• Upper/lower flammability or explosive limits
• Odor
• Vapor pressure
• Odor threshold
• Vapor density
• pH
• Relative density
• Melting point/freezing point
• Solubility(ies)
• Initial boiling point and boiling range
• Partition coefficient: n-octanol/water
• Flash point
• Auto-ignition temperature
• Evaporation rate
• Decomposition temperature
• Flammability (solid, gas)
• Viscosity
Every item listed above may not be relevant or available. When this occurs, a
notation to that effect must be made for that chemical property.
Manufacturers may also add other relevant properties.
Section 10: Stability and Reactivity
Describes the reactivity hazards of the chemical and the chemical stability
information. Required information consists of:
• Reactivity
o Description of the specific test data for the chemical(s). This
data can be for a class or family of the chemical if such data
adequately represent the anticipated hazard of the
chemical(s), where available.
• Chemical stability
o Indication of whether the chemical is stable or unstable
under normal ambient temperature and conditions while in
storage and being handled
o Description of any stabilizers that may be needed to maintain
chemical stability
o Indication of any safety issues that may arise should the
product change in physical appearance
• Other
o Indication of the possibility of hazardous reactions, including
a statement as to whether the chemical will react or
polymerize, which could release excess pressure or heat, or
create other hazardous conditions
o Description of the conditions under which hazardous
reactions may occur
o List of all conditions that should be avoided
o List of all classes of incompatible materials with which the
chemical could react to produce a hazardous situation
o List of any known or anticipated hazardous decomposition
products that could be produced because of use, storage or
heating
Section 11: Toxicological Information
Identifies toxicological and health effects information or indicates that such
data are not available. Required information consists of:
• Information on the likely routes of exposure: inhalation, ingestion
and/or skin and eye contact
o The SDS should indicate if the information is unknown
• Description of the delayed, immediate or chronic effects from short-
and long-term exposure
• The numerical measures of toxicity
• Description of the symptoms
o This description includes the symptoms associated with
exposure from the lowest to the most severe exposure
• Indication of whether the chemical is listed in the National Toxicology
Program (NTP) Report on Carcinogens or has been found to be a
potential carcinogen in the International Agency for Research on
Cancer (IARC) Monographs or found to be a potential carcinogen by
OSHA
Section 12: Ecological Information (non-mandatory)
Provides information to evaluate the environmental impact of the chemical(s)
if it were released to the environment. The information may include:
• Data from toxicity tests performed on aquatic and/or terrestrial
organisms, where available
• Whether there is a potential for the chemical to persist and degrade in
the environment either through biodegradation or other processes,
such as oxidation or hydrolysis
• Results of tests of bioaccumulation potential, making reference to the
octanol-water partition coefficient and the bioconcentration factor
where available
• The potential for a substance to move from the soil to the groundwater
• Other adverse effects: environmental fate, ozone layer depletion
potential, photochemical ozone creation potential, endocrine
disrupting potential and/or global warming potential
Section 13: Disposal Considerations (non-mandatory)
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 should also refer the reader to Section 8 (Exposure
Controls/Personal Protection) of the SDS. The information may include:
• Description of appropriate disposal containers to use
• Recommendations of appropriate disposal methods to employ
• Description of the physical and chemical properties that may affect
disposal activities
• Language discouraging sewage disposal
• Any special precautions for landfills or incineration activities
Section 14: Transport Information (non-mandatory)
Provides guidance on classification information for shipping and transporting
of hazardous chemical(s) by road, air, rail or sea. The information may
include:
• UN number
• UN proper shipping name
• Transport hazard class(es)
• Packing group number, if applicable, based on the degree of hazard
• Environmental hazards
• Guidance on transport in bulk
• Any special precautions an employee should be aware of or needs to
comply with, in connection with transport or conveyance either
within or outside their premises
Section 15: Regulatory Information (non-mandatory)
Identifies any national and/or regional safety, health and environmental
regulations specific for the product that are not indicated anywhere else on
the SDS.
Section 16: Other Information
Indicates when the SDS was prepared or when the last known revision was
made. The SDS may also state where the changes have been made to the
previous version. Other useful information also may be included here.
SDSs are the backbone of the Hazard Communication Standard. They provide
comprehensive and specific chemical information used not only by
workplaces that manufacture, use, transport or store hazardous chemicals,
but also by emergency responders, poison control centers and transporters
of dangerous goods. The revised Hazard Communication Standard provides a
single set of harmonized criteria for classifying chemicals and also stipulates
specific hazard communication elements for SDS labeling, all in an effort to
help improve the safety and health protections for America’s workers.
Q: What are the major changes to the revised Hazard Communication
Standard?
A: The three major areas of change in the revised Hazard Communication
Standard are in hazard classification, labels and safety data sheets.
• Hazard classification: The definitions of hazard have been changed to
provide specific criteria for classification of health and physical
hazards, as well as classification of mixtures. These specific criteria
will help to ensure that evaluations of hazardous effects are
consistent across manufacturers, and that labels and safety data
sheets are more accurate as a result.
• Labels: Chemical manufacturers and importers will be required to
provide a shipped to container label that includes a harmonized
signal word, pictogram and hazard statement for each hazard class
and category. Precautionary statements must also be provided.
• Safety Data Sheets: Will now have a specified 16-section format.
Q: The United Nations revises the Globally Harmonized System of
Classification and Labeling of Chemicals (GHS) every two years. How will
OSHA communicate changes to the Hazard Communication Standard going
forward?
A: OSHA anticipates that future updates of the Hazard Communication
Standard (HCS) may be necessary and can be done through various
rulemaking options, including:
• Technical updates for minor terminology changes
• Direct Final Rules for text clarification
• Notice and Comment rulemaking for more substantive or controversial
updates such as additional criteria or changes in health or safety
hazard classes or categories
Q: What is the phase-in period for the revised Hazard Communication
Standard?
A: The table below summarizes the phase-in dates required under the revised
Hazard Communication Standard (HCS):
Effective
Completion
Date
Requirement(s)
Responsible Party(ies)
December 1,
2013
Train employees on the new
label elements and SDS
format.
Employers
June 1, 2015
December 1,
2015
Comply with all modified
provisions of the final rule,
except:
Distributors may ship
products labeled by
manufacturers under the old
system until December 1,
2015.
Chemical manufacturers,
importers, distributors and
employers
June 1, 2016
Update alternative
workplace labeling and
hazard communication
program as necessary, and
provide additional employee
training for new identified
physical or health hazards.
Employers
Transition
Period
Comply with either the
revised final standard, the
current standard, or both.
All chemical
manufacturers, importers,
distributors and employers
Q: When must the Safety Data Sheets be updated?
A: If the preparer of an SDS becomes aware of any significant new
information regarding the hazards of the chemical, or ways to protect against
the hazards, than this new information must be added to the SDS within
three months.
The parts of the HCS not related to the GHS–basic framework, scope and
exemptions–have remained largely unchanged.
The Standard comprises six major categories: Hazard Determination, Safety
Data Sheets, Labels and other Forms of Warning, Employee Information and
Training, The Written Hazard Communication Program and Trade Secrets.
The first category, Hazard Determination (29 CFR 1910.1200 (d)) requires
employers to identify and evaluate all chemicals used in the workplace. This
evaluation is based on two hazard categories: listed and defined.
Listed hazards are those included in one of the following references: OSHA
29 CFR 1910.1000 Z tables; American Conference of Governmental Industrial
Hygienists (ACGIH) Threshold Limit Values (TLV); the National Toxicology
Program; or the International Agency for Research on Cancer.
Defined hazards are specified by OSHA as physical or health hazards, such
as combustible liquids, oxidizers, corrosives, reproductive toxins and non-
toxins.
Chemicals exempt from the standard include: wood and wood products
(except wood dust), regulated hazardous waste, tobacco products, food,
drugs, cosmetics, alcoholic beverages, agricultural or vegetable seed treated
with pesticides, various types of pesticides, nuisance particulate, and
articles. These are exempt because they are all regulated by separate
government agencies.
The second major category of the Standard is SDS (29 CFR 1910.1200(g)).
Once you have evaluated and identified all of the hazardous chemicals in
your workplace, you must document them and obtain an SDS for each item.
SDS are available from the chemical supplier or manufacturer. These SDS'
contain specific chemical hazard information such as: physical hazards,
health hazards, routes of entry, exposure limits (if any), precautions for safe
handling and use (if known), spill clean-up procedures, personal protective
equipment to be used, emergency and first-aid procedures, and the name,
address and telephone number of the chemical manufacturer. All of the
information on the SDS must be in English and be available to employees
working with or near the hazardous chemical.
The third category, Labels and other Forms of Warning (29 CFR 1910.1200(f)),
requires labels on all chemicals in the workplace. The label should contain
the identity of the material, appropriate hazard warnings and the name and
address of the manufacturer, importer or other responsible party. Other
appropriate warning information (such as pictures and symbols) may be used
in conjunction with the hazard information. Labels must be legible and in
English. Labels in a second language may be added as long as the English
label is present. For more information on labeling, please refer to Quick Tips
#198, "HazCom and Comparing Chemical Labeling Requirements."
The fourth category, Employee Information and Training (29 CFR
1910.1200(h)), requires employers to provide employees with effective
information and training on hazardous chemicals in their work area at the
time of their initial assignment and whenever a new physical or health
hazard is introduced into the area. The training shall include: methods and
observations used to detect the presence or release of the chemical,
physical and health hazards, protective measures, labeling and explanation
of the SDS.
The fifth category is the Written Hazard Communication Program (29 CFR
1910.1200(e)). It requires employers to fully document the actions taken to
comply with all of the provision of the Standard and to list the responsible
person(s) for each area of the program. A copy of the written program must
be made available, upon request, to all employees and OSHA officials.
The sixth and final category of Hazard Communication involves manufacturer
Trade Secrets (29 CFR 1910.1200(i)). The chemical manufacturer may
withhold the chemical identity, including the chemical name and other
specific information, from the SDS. However, under special conditions, this
secret information may be obtained by health care professionals.
There have been some minor terminology modifications to align the revised
HCS language with that used in the GHS. For example, the term "hazard
determination" has been changed to "hazard classification" and "material
safety data sheet" (MSDS) has changed to "safety data sheet" (SDS).
Major Changes
The three major areas of change are hazard classification, labels and safety
data sheets.
The definitions of hazard have been changed to provide specific criteria for
classification of health and physical hazards and for the classification of
mixtures. These will help ensure that evaluations of hazardous effects are
consistent across the board and labels and safety data sheets are therefore
more accurate.
Chemical manufacturers and importers will be required to provide a
harmonized label that has six standardized elements for classified hazards:
• Product Identifier–Must match product identifier on safety data sheet.
• Manufacturer Contact Information–Including name, phone number, and
address.
• Hazard Pictograms–There are nine pictograms used to convey the
health, physical and environmental hazards. HCS requires eight of
these pictograms, the exception being the environmental pictogram
as environmental hazards are not within OSHA's jurisdiction. These
pictograms will have a black symbol on a white background with a
red diamond frame (see illustrations below):
• Signal Word–Either DANGER or WARNING depending upon hazard
severity.
• Hazard Statements–Standardized sentences that describe the level of
the hazards.
• Precautionary Statements–Steps employees can take to protect
themselves.
OSHA has indicated that it will continue to give employers the flexibility to
determine what types of workplace labels will be required. Employers have
the ability to choose to label workplace containers either with the same
label that the chemical manufacturer or importer used on shipped containers
or with alternate labels that meet the requirements of the standard.
Safety data sheets (SDS) remain the backbone of HCS. With the revision
there is a name and formatting change. The M is dropped from MSDS and
more importantly a standardized 16 section format with a required ordering
of sections is mandatory. This format is essentially the American National
Standard for Hazardous Workplace Chemicals–Hazard Evaluation and Safety
Data Sheet and Precautionary Labeling Preparation, ANSI Z400.1/Z129.1-
2010.
Effective Dates
Employers must train workers on the new label elements and SDS format by
December 1, 2013. Chemical manufacturers, importers, distributors, and
employers must comply with all modified provisions of the final rule by June
1, 2015. However, distributors may ship products labeled by manufacturers
under the old system until December 1, 2015. By June 1, 2016, employers
must update alternative workplace labeling and hazard communication
programs as necessary, and provide additional worker training for new
identified physical and health hazards.
The table below summarizes the phase-in dates required under the revised
Hazard Communication Standard (HCS):
Effective
Completion
Date
Requirement(s)
Who
December 1,
2013
Train employees on the new label
elements and safety data sheet (SDS)
format.
Employers
June 1, 2015∗
December 1,
2015
Compliance with all modified provisions
of this final rule, except: The Distributor
shall not ship containers labeled by the
chemical manufacturer or importer
unless it is a GHS label
Chemical
manufacturers,
importers,
distributors and
employers
June 1, 2016
Update alternative workplace labeling
and hazard communication program as
necessary, and provide additional
employee training for newly identified
physical or health hazards.
Employers
Transition
Period to the
effective
completion
dates noted
above
May comply with either 29 CFR
1910.1200 (the final standard), or the
current standard, or both
Chemical
manufacturers,
importers,
distributors,
and employers
During the transition period, all chemical manufacturers, importers,
distributors, and employers may comply with either the current, revised or
both 29 CFR 1910.1200 standards.
When HCS first took effect in 1985, employees got the right-to-know what
their potential exposure to hazards might be. With this revision, employees
not only know about the potential hazards, they also have a better
understanding of what the warnings mean, what to do if exposed and how to
protect themselves. All employees will be provided with the same
information in the same format.
Q.
Are employers required to maintain two sets of labels and safety data
sheets during the transition period?
A.
No, during the transition period, all chemical manufacturers, importers,
distributors, and employers may comply with either the existing HCS or
the revised HCS, or both. During this time hazard communication
programs may go through a period where labels and safety data sheets
under both standards will be present. OSHA considers this acceptable
and two sets of labels and safety data sheets are not required.
Q.
Why must training be conducted prior to the compliance effective
date?
A.
Many countries are in the process of implementing GHS. Therefore, it is
possible that workplaces may begin to receive GHS compliant labels
and safety data sheets much before December 1, 2015. When
employees begin to see the new labels and safety data sheets, they
must understand the information that is being provided.