Search

Valuable Insights in Latest OSHA GHS HazCom Enforcement Memo

Posted on 7/21/2015 by Roger Marks

Now that the June 1 deadline for GHS compliance has come and gone, and chemical manufacturers, importers, and distributors have shifted to new chemical classification, marking, labeling, and documentation criteria, one big question remains: How will OSHA enforce the new GHS Hazard Communication (HazCom) standard?

An instructional memo for OSHA compliance officers released by the Department of Labor provides insight into the answer.

The Latest GHS HazCom Guidance for Inspectors

The instructional memo, released by the Department of Labor on July 20, provides OSHA compliance officers with a breakdown of the new requirements, critical definitions of GHS terms, guidelines for issuing citations, and more. Read the full July 20 OSHA GHS memo here.
GHS hazard communication chemical labels
Which Revision of the GHS to Follow

The GHS is a living, changing standard from the United Nations, currently in its 4th revision. In 2012, OSHA adopted standards from Revision 3 of the GHS, and OSHA enforcement of its HCS is based on this Revision.

As the new memo lays out, this is significant because, in some cases, compliance with the latest UN GHS rules (Revision 4) can cause noncompliance with the standards OSHA adopted (Revision 3). For example: GHS Revision 4 introduced a new hazard category for nonflammable aerosols, which do not require hazard pictograms and labels. But under the rules OSHA adopted (Revision 3), these same nonflammable aerosols meet the criteria of a compressed gas and would require an appropriate label and pictogram.

Failure to appropriately label these products would result in an OSHA citation. In other words, by complying with the latest GHS rules from the UN, facilities may be out of compliance with the Revision 3 rules OSHA adopted. So, industry must comply with the current OSHA HazCom Standard and await OSHA’s adoption and implementation of newer GHS rules.

Previous GHS HazCom Guidance from OSHA

A June 2015 memo to OSHA compliance officers also shed light on some important elements of GHS enforcement. First, it detailed which chemical companies are considered “manufacturers” under the OSHA HCS rules. Second, the memo provides guidance for other industry sites that have not yet received updated, GHS-compliant labels or Safety Data Sheets from suppliers. v What Is GHS?

OSHA’s Hazard Communication Standard (HCS) is intended to protect employees who work around or handle hazardous chemicals. The Standard changed in 2012 when OSHA officially adopted certain elements of the Globally Harmonized System for Classification and Labeling of Chemicals—“GHS” for short.

Specifically, OSHA’s adoption of the GHS hazardous communication rules—also called HazCom 2012—requires the use of new chemical classification criteria, labels, and Safety Data Sheets.

OSHA required employers who use hazardous chemicals in the workplace to provide “right-to-understand” HazCom training for all employees before December 1, 2013. As of June 1, 2015, chemical manufacturers, importers, and distributors must provide their customers with new 16-section Safety Data Sheets and chemical containers that bear new labels.

OSHA GHS Compliance Training – July 23

Help your site transition smoothly to the new GHS Hazard Communication Standard for chemicals. Join us for the live, instructor-led OSHA GHS Compliance Webinar on July 23 to learn how OSHA’s GHS adoption will impact your operations, including new labeling requirements, switching from MSDSs to SDSs, and what to expect in the future.

Tags: GHS, HazCom, materials handling, osha, Safety Data Sheets

Find a Post

Compliance Archives

Lion - Quotes

These are the best classes I attend each year. I always take something away and implement improvements at my sites.

Kim Racine

EH&S Manager

The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.

George Alva

Manufacturing Manager

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

The instructor was very engaging and helped less experienced people understand the concepts.

Steve Gall

Safety Leader

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

I love that the instructor emphasized the thought process behind the regs.

Rebecca Saxena

Corporate Product Stewardship Specialist

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

The instructor made the class very enjoyable and catered to the needs of our group.

Sarah Baker

Planner

Download Our Latest Whitepaper

Find out what makes DOT hazmat training mandatory for employees who sign the hazardous waste manifest, a “dually regulated” document for tracking shipments.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.