Q: I am in charge of overseeing my company’s transition to OSHA’s new GHS Hazard Communication Standard. How much of the standard will be changing?
A: The overhaul to OSHA’s Hazard Communication System (HCS) has caused anxiety nationwide in many industries since the rulemaking was announced—but while many aspects of hazard communication will change, the major thrust of “HazCom” scope and application will remain the same.
OSHA’s adoption of the Globally Harmonized System (GHS) brings major changes for any employer whose personnel handle hazardous chemicals at work; there are new chemical classification criteria to follow, revised markings and labels to recognize, and new 16-section Safety Data Sheets to fill out.
Intent of the OSHA HazCom Standard
The intent of OSHA’s HazCom standard has not changed. OSHA requires employers to alert personnel to hazards in the workplace through container marking and labeling, documentation, and effective training. These requirements have always been a part of OSHA’s Hazard Communication Standard, found at 29 CFR 1910.1200.
Just as before the GHS rulemaking, chemical manufacturers/importers must classify “hazardous chemicals,” accurately label containers of chemicals they ship out, and clearly document those hazards on paper. The employers’ obligation to create a written program of training and workplace communication still stands.
Most of the exclusions under the old HazCom rule also still apply. For instance, certain types of chemicals need not be labeled, such as food and drugs subject to FDA labeling and pesticides subject to FIFRA labeling. Still exempt from HazCom are RCRA-regulated hazardous wastes, personal medication taken by employees, and biological hazards.
Though the “HazCom 2012″ GHS initiative will require more disclosure with respect to chemicals manufactured, handled, and shipped, trade secrets are still protected under an exemption [29 CFR 1910.1200(i)].
GHS HazCom Training Options
To help the regulated community navigate the new GHS requirements, Lion offers three training options. With training for all levels you can ensure that all employees are in compliance by the December 1, 2013 deadline.