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

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