All-Pro Occupational Trainers, Inc. provides training to employees and employers who handle or are exposed to hazardous materials. The employer, under OSHA, has to follow certain guidelines and implement specific documentation (Written Plan and Chemical Inventory) within this standard.
Hazard Communication (HazCom) & Globally-Harmonized System (GHS)
OSHA’s Hazard Communication Standard is designed to protect employees from hazardous chemicals used or stored in the work setting. Also referred to as the Right-To-Know Law, it requires that HazCom training and information be provided to any employee who have the potential of being exposed to a hazardous chemical “under normal condition of use or in a foreseeable emergency.”
The “Right to Understand”
OSHA says that the Hazard Communication Standard in 1983 gave workers the “right to know”, but aligning the HCS with the Globally Harmonized System gives workers the “right to understand”
HazCom training requires the presence of hazardous chemicals be communicated to the employees in a variety of ways, including:
- The hazardous chemical inventory
- Material Safety Data Sheets (MSDS)/Safety Data Sheets (SDS)
- Labels, tags or signs
- The written hazard communication program
OSHA has issued a final rule to align its Hazard Communication Standard with the Globally Harmonized System of Chemical Classification and Labeling (GHS). The changes focus on:
- Hazard classification
- Labeling and marking
- Safety Data Sheets (SDS)
- Information distribution and training
Why must training be conducted prior to the compliance effective date?
OSHA is requiring that employees are trained on the new label elements (i.e., pictograms, hazard statements, precautionary statements, and signal words) and SDS format by December 1, 2013, while full compliance with the final rule will begin in 2015. American workplaces will soon begin to receive labels and SDSs that are consistent with the GHS, since many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDSs. It is important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they will be familiar with them, understand how to use them, and access the information effectively.
Compliance Dates for the Revised HazCom Standard
The revised Hazard Communication Standard, found at CFR29.1910.1200, took effect May 25th, 2012 (60 Days after publication in the Federal Register). However, OSHA has provided the following extended compliance dates to meet the new requirements.
- December 1st, 2013 - Train Employees on the new label elements and SDS Format
- June 1st, 2013 - Comply with all modified provisions of the final rule, except:
December 1st, 2013 Distributors may ship products labeled ny manufacturers under the
old systme until December 1st, 2015
- June 1st, 2016* - Update alternative workplace labeling and hazard communication program as
necessary, and provide additional employee training for newly identified physical
or health hazards.
- Transition Period - Comply with either 29CFR1910.1200 (this final standard) or the current standard,
- *This Date coincides with the European Union implementation date for classification of mixtures.
Other U.S. Agencies: The Department of Transportation (DOT), Environmental Protection Agency, and the Consumer Product Safety Commission actively participated in developing the GHS. DOT has already modified its requirements for classification and labeling to make them consistent with United Nations transport requirements and the new globally harmonized system.
Global implementation: The new system is being implemented throughout the world by countries including Canada, the European Union, China, Australia, and Japan.