From: "Secretary, ACS Division of Chemical Health and Safety" <secretary**At_Symbol_Here**DCHAS.ORG>
Subject: [DCHAS-L] OSHA QuickTakes Special Issue on Haz Comm and GHS
Date: March 22, 2012 10:40:57 AM EDT
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March 22, 2012 =B7 Volume 11, Issue 7

OSHA Aligns Hazard Communication Standard with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals

On March 20, Secretary of Labor Hilda L. Solis, joined by Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels, hosted a press teleconference to announce a final rule updating OSHA's Hazard Communication Standard.

Secretary Solis described that the revised standard will align with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals to better protect workers from hazardous chemicals and help American businesses compete in a global economy. "Exposure to hazardous chemicals is one of the most serious dangers facing American workers today," she said. "Revising OSHA's Hazard Communication Standard will improve the quality, consistency and clarity of hazard information that workers receive, making it safer for workers to do their jobs and easier for employers to stay competitive in the global marketplace."

Assistant Secretary Michaels explained that OSHA's revised Hazard Communication standard (HCS), which will be fully implemented in 2016, benefits workers by reducing confusion in the workplace, facilitating safety training, and improving understandings of hazards, especially for low-wage and limited-literacy workers. The harmonized standard will classify chemicals according to their health and physical hazards, and establish consistent labels and safety data sheets for all chemicals made in the United States or imported from abroad. For more information, listen to an audio-recording of the press conference and see the press release.
About OSHA's Hazard Communication Standard (HCS)

Chemicals pose a wide range of health hazards (such as irritation, sensitization, and carcinogenicity) and physical hazards (such as flammability, corrosion, and reactivity). OSHA's Hazard Communication Standard (HCS), first issued in 1983, is designed to ensure that employers provide information about these hazards and associated protective measures to their workers.

This is accomplished by requiring chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import, and to provide information about them through labels on shipped containers and more detailed information sheets called safety data sheets (SDSs). All employers with hazardous chemicals in their workplaces must prepare and implement a written hazard communication program, and must ensure that all containers are labeled, workers are provided access to SDSs, and an effective training program is conducted for all potentially exposed workers.

The HCS gives workers the right to know the hazards and identities of the chemicals they are exposed to in the workplace. When workers have this information, they can participate in their employers' protective programs and take steps to protect themselves. More information about the HCS and workers' right-to-know can be found here.
The Right to Understand

Workers have sometimes had difficulty understanding information presented on safety data sheets (SDSs). In some cases the length and complexity of the documents have made it difficult for workers to locate important safety information. In one testimony, a hospital safety director described a situation in which a worker was unable to find critical information on an SDS in an emergency situation:

". . . two gallons of the chemical xylene spilled in the lab of my hospital. By the time an employee had noticed the spill, the ventilation had already sucked most of the vapors into the HVAC. This, in turn, became suspended in the ceiling tile over our radiology department. Twelve employees were sent to the emergency room. To make the matter worse, the lab employee was frantically searching through the binder in her area for [the SDS for] xylene. Once she found it, she had difficulty locating the spill response section. After notifying our engineering department, she began to clean up the spill with solid waste rags, known for spontaneous combustion, and placing the rags into a clear plastic bag for disposal. She did not know that xylene has a flash point of 75 degrees Fahrenheit. She then walked the bag down to our incinerator room and left it there, basically creating a live bomb. Twelve people were treated from this exposure. The lab employee was very upset and concerned about the safety of the affected employees and visitors, and hysterically kept stating that she could not find the necessary spill response information."

OSHA's harmonized standard will ensure that workers have access not only to labels and safety data sheets, but also to information that is easier to find and understand through the use of standardized formats and label elements: signal words, pictograms, hazard statements, and precautionary statements. As one participant expressed during OSHA's rulemaking process, this update will give workers the right to understand, as well as the right to know.
What is the Globally Harmonized System (GHS)?

The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets. These criteria and elements will help chemical manufacturers to determine if a chemical product produced and/or supplied is hazardous and explains how to prepare an appropriate label and/or safety data sheet.

The GHS is not a regulation or a standard, but a set of recommendations that a competent authority such as OSHA can adopt.

The GHS is being implemented around the world in countries such as Australia, the EU, and China. The GHS Document (shown at the right) provides countries with the regulatory building blocks to develop or modify existing national programs that address classification of hazards and transmittal of information about those hazards and associated protective measures. This helps to ensure the safe use of chemicals as they move through the product life cycle and around the world. More information about GHS and The Purple Book is available here.
Why Modify HCS?

OSHA's adoption of the GHS won't change the framework and scope of the current HCS, but will help ensure improved quality and more consistency of hazard information in the workplace, making it safer for workers to do their jobs and easier for employers to stay competitive.

Aligning the HCS with the GHS will 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. The harmonized format of the safety data sheets will enable workers to access the information more efficiently.

In addition, under the current system, multiple labels and safety data sheets must often be developed for the same product when shipped to different countries. This creates a major compliance burden for chemical manufacturers and those involved in international trade, increasing the cost of providing hazard information. The adoption of GHS will reduce trade barriers and minimize this burden.
Benefits of Harmonization

Exposure to hazardous chemicals is one of the most serious threats facing American workers today. Revising OSHA's Hazard Communication Standard will improve the quality and consistency of hazard information, making it safer for workers to do their jobs and easier for employers to stay competitive.

Benefits to workers and members of the public include consistent, simplified communications on chemical hazards, safe handling practices, greater awareness of hazards, and overall safer use of chemicals. Benefits to employers include safer work environments, improved relations with workers, increased efficiency, reduced costs of compliance, and expanded use of training programs on health and safety.

For more information about the benefits of harmonization, visit OSHA's Guide to the GHS.

Changes to Anticipate
The revised Hazard Communication Standard will now provide specific criteria for health and physical hazards to help chemical manufacturers and importers classify chemical hazards. Hazard classification is the procedure of identifying and evaluating available scientific evidence to determine if a chemical is hazardous, and the degree of the hazard.

Chemical manufacturers and importers will be required to provide new labels that include a harmonized signal word, pictogram, and hazard statement based on the hazard classification. Precautionary statements must also be provided. Safety data sheets (SDS) will have a specified 16-section format.

The modified HCS will also require that workers receive information and training by December 1, 2013 to facilitate recognition and understanding of the new labels and safety data sheets.
What Do the New Pictograms Look Like?
There are nine pictograms under the GHS to convey the health, physical and environmental hazards. The final Hazard Communication Standard requires eight of these pictograms, the exception being the environmental pictogram, as environmental hazards are not within OSHA's jurisdiction. The hazard pictograms and their corresponding hazards are shown below.

What Employers Need to Do and When (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. During this transition period, all chemical manufacturers, importers, distributors, and employers may comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both.

For more information about the phase-in dates required under the revised Hazard Communication Standard, see the chart on OSHA's effective dates.
Educational Materials on HCS and GHS Now Available

OSHA has issued several new educational resources to provide workers and employers helpful information about OSHA's harmonized Hazard Communication Standard. QuickCards on safety data sheets, labels and pictograms are available here in both English and Spanish. More details about OSHA's Hazard Communication Standard Final Rule are also available in OSHA's new fact sheet.
For Additional Information

OSHA's new harmonized Hazard Communication page.
Further information for workers, employers and downstream users of hazardous chemicals can be reviewed at OSHA's Safety and Health Topics page on Hazard Communication, which includes links to OSHA's revised Hazard Communication Standard and guidance materials such as frequently asked questions, QuickCards, and OSHA's Guide to the GHS.

See DOL's weekly electronic newsletter for more DOL news.

For more frequent updates on OSHA activities follow DOL on Twitter and Facebook.

Ralph Stuart
Division of Chemical Health and Safety
American Chemical Society

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