OSHA Updates HazCom Rule to Sync with GHS
Saturday 02 June 2012 at 12:00 am.
The OSHA Hazard Communication Standard (HCS - 29 CFR §1910.1200) has now been aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update to the Hazard Communication Standard (HCS) will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. This rule was codefied in March and went into effect on May 26, 2012.
The OSHA GHS rule specifies label, safety data sheet (SDS) and training information. Labels on containers must include an identifier, signal word, hazard statements, pictograms, precautionary statements and contact information for the responsible party. Safety Data Sheets (as they will be known, replacing the previous MSDS term) will follow an ANSI-like 16-section format. This will be a relatively minor change for companies already using such a format. The biggest difference will be in the hazards identification (Section 2). A more disciplined approach to substance or mixture classification has been constructed for the assignment of signal word, hazard statements, pictograms and precautionary statements. While the new standard under OSHA does not specify the contents of Sections 12 through 15 (Ecological, Disposal, Transport and Regulatory Information), these sections must be included for consistency with the GHS.
OSHA has also set out stricter conditions for the use of compositional trade secrets. Specific chemical identity and exact percentages can still be masked, provided the responsible party has a bona fide claim that a trade secret can be supported. In emergency situations this information must be provided to responding personnel, if needed. Non-emergency requests for such information must be in writing and can either be addressed freely, under a CDA or denied with supporting reasons for not disclosing the confidential or trade secret information (along with the reason why alternate information will satisfy the request without revealing the trade secret).
Although the final rule has come into force, OSHA has set up a transitional period for its implementation. Chemical manufacturers, importers, distributors, and employers may comply with either §1910.1200 revised as of October 1, 2011, or the current version of this standard, or both during the transition period. OSHA has set a date of June 1, 2015 for full compliance with the new standard (distributors have until December 1, 2015). Training of all employees regarding the new label elements and SDS must be conducted by December 1, 1013.