This is the year when most regulations of OSHA’s Global Harmonization of the Hazard Communications Standard takes effect. Manufacturers of hazardous chemicals are required to use new labels and to provide safety data sheets by June 1, 2015. Those who use hazardous chemicals in the workplace are to have trained employees on the Globally Harmonized System (GHS) of hazard communications by December 1, 2013. Are you currently in compliance and will you be ready to meet your company’s other obligations under the standard by June 1, 2015?
If you provided training to employees ahead of the December 1, 2015 date you are one step ahead of many companies. Lack of training was the number one cited issue under Haz Com standard citations last year. Please remember that employees hired after your initial training session also need to be trained. In fact, you may want to think about providing a training session for everyone this year prior to the June 1 date. You will be able to provide specific examples of proper labeling and safety data sheets for products your employees use. This will help increase the awareness level of your employees for handling hazardous chemicals.
Don’t complicate the training. The main areas to address under the new rules involve: 1) the use of pictograms to symbolize hazards on the labels and 2) the new required format for Safety Data Sheets. Many elements of the hazard communications standard remain the same. These two areas should be the focus of your training for those who have received hazard communications training in the past. There are many resources for training materials. Check out our resource page for links to the OSHA website, Northwest Independent Contractors Association and other sites with safety training materials.
If you manufacture chemicals that are classified as hazardous under the globally-harmonized system, you most-likely are in the process of determining the label information you will need to provide on your products as well as developing new safety data sheets for those products. If you are still looking for direction on this, here is a link to the OSHA document that outlines the system including hazard classification, label requirements and the safety data sheet format.
Under the OSHA regulations, combustible dust is considered a physical hazard even though it is not classified specifically as hazardous under Global Harmonization. This means that if you manufacture a product that in and of itself constitutes a dust hazard or if it creates a combustible dust when processed i.e. certain metals, plastics, wood or grain you are subject to labeling and safety data sheet requirements. We will be watching for guidance from various industry groups over the next few months to help companies understand how they are expected to meet these requirements. There have been some letters of interpretation posted on the topic. You can find the letters at this link.
As your company begins to receive Safety Data Sheets, be sure to update your safety data sheet binders or other system with this new information. Old material safety data sheets should be retained for 30 years or in the alternative you are required to maintain a list of each chemical used and when and where it was used. This must be maintained for 30 years.
Workplace container labeling requirements are not to take effect until June 1, 2016. We will address this topic more fully in another post.
The format for a written program remains similar to what OSHA has required in the past. Main changes are to reference the new labeling requirements (pictograms) and safety data sheets versus material safety data sheets. The small entity guide referenced at the end of this blog contains a sample written program.
GHS is here to stay and will impact nearly all businesses in some manner during the first part of 2015. Make use of the resources already mentioned. Another helpful publication is OSHA’s Small Entity Compliance Guide. The guide is a helpful resource that will guide businesses through the process of establishing a hazard communications program that meets the new GHS requirements.
Please contact us if you have questions or need further assistance.
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