Lion's office will be closed on Friday, July 4, in observance of Independence Day. For help with online training, please contact support@lion.com.
Search

Question of the Week: Hazard Communication: GHS Is Coming

Posted on 9/14/2011 by James Griffin

Q. I’ve heard that OSHA is about to finalize a new Hazard Communication Standard that will change everything we’re currently doing under the standard. Is that true?
 
A. OSHA is planning to finalize a new Hazard Communication Standard (29 CFR 1910.1200) before the end of 2011; however, the proposed changes would not change “everything” that employers are presently required to do under the standard. The proposed changes to the Hazard Communication Standard will essentially affect three things:
 
  1. Hazard classification
  2. Required elements on container labels
  3. Required information and format of “Material Safety Data Sheets”
Hazard Classification Under the New Rule
The new standard will adopt the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) system for classifying hazards. As a result, the definitions of the various physical and health hazards will be different, although not radically so. In addition, the new system will include “unclassified hazards.” These would be chemicals that evidence indicates may pose adverse physical or health effects when present in the workplace under normal conditions of use or in a foreseeable emergency, but that do not currently meet any of the specified criteria for physical or health hazard classification. One possible example under this last category might be explosive dusts.
 
Labels Under the New Rule
The new standard will require “GHS labels” to be placed on all shipped containers. The label will need to include a harmonized signal word, standard pictogram(s), and hazard and precautionary statements for each hazard class and category posed by the chemical.
 
Required Information and Format of “Material Safety Data Sheets”
Under the new rule, Material Safety Data Sheets will become Safety Data Sheets. The Safety Data Sheets will follow the same 16-section format as the ANSI standard for Safety Data Sheets (ANSI Z400.1). Of these 16 sections, 12 will be mandatory and four will be optional because they consist of information that is beyond OSHA’s scope of enforcement (e.g., transportation-related information). In addition, the new standard will include a new mandatory Appendix D that will identify information that is required in each section of the Safety Data Sheet.
 
Elements of the Standard That Are Not Expected to Change Under the New Rule
The overall framework of the Hazard Communication Standard is expected to remain unchanged. As proposed, there will be no substantive changes made to:
 
  • The scope and application of the standard
  • The requirements for a written hazard communication program
  • Training of employees working with or exposed to hazardous chemical in their workplace
  • The requirements for dealing with trade secrets
In addition, even though changes are being made to how chemicals are classified and the required information on labels and Safety Data Sheets, the other components of classification, labeling, and Safety Data Sheets will remain the same. For example:
 
  • Classification will still be the responsibility of the chemical manufacturer or importer, and the employer will still be able to rely on this classification.
  • Requirements for labels to be legible, in English, and prominently displayed remain unchanged, and materials and activities excluded from labeling under the current standard are expected to remain excluded under the new standard.
  • MSDS requirements for distribution, maintenance in workplace, accessibility to employees, etc. will essentially remain unchanged.
 
Expected Date of the New Rule
OSHA indicated in the 2011 Spring Semiannual Regulatory Agenda that the proposed rule was expected to be finalized and published by September, 2011. At the moment, however, OSHA has not submitted the final rule to the Office of Management and Budget (OMB), a necessary final step in the process of promulgating a new rule. Once a rule has been submitted to the OMB, it typically takes between 30 and 60 days before the rule can be finalized and published in the Federal Register. Because of this, while it is still entirely possible that the new rule will come out by the end of 2011, it is somewhat unlikely that it will appear before the end of September 2011.
 

Tags: GHS, HazCom, marks and labels, osha

Find a Post

Compliance Archives

Lion - Quotes

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.

Ellen Pelton

Chemical Laboratory Manager

The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked.

Johnny Barton

Logistics Coordinator

Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.

Dorothy Rurak

Environmental Specialist

Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!

Marti Severs

Enterprise Safety Manager

The instructor does a great job at presenting material in an approachable way. I have been able to save my company about $30,000 in the last year with what I have learned from Lion!

Curtis Ahonen

EHS&S Manager

This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!

Lori Hardy

Process & Resource Administrator

Lion's information is very thorough and accurate. Presenter was very good.

Melissa Little

Regulatory Manager

Download Our Latest Whitepaper

This guide will help you identify 25 of the most -cited errors in RCRA training, recordkeeping, hazardous waste ID, container management, universal waste, and laboratories.

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.