Wednesday, December 26, 2012

New Hazard Communication Standard Q & A: Part 4

Q. What Hazard Communication Standard provisions are unchanged in the revised HCS?

A. The revised Hazard Communication Standard (HCS) is a modification to the existing standard. The parts of the standard that did not relate to the GHS (such as the basic framework, scope, and exemptions) remained largely unchanged. There have been some modifications to terminology in order to align the revised HCS with language used in the GHS. For example, the term "hazard determination" has been changed to "hazard classification" and "material safety data sheet" was changed to "safety data sheet." OSHA stakeholders commented on this approach and found it to be appropriate.

Q. How will chemical hazard evaluation change under the revised Hazard Communication Standard?

A. Under both the current Hazard Communication Standard (HCS) and the revised HCS, an evaluation of chemical hazards must be performed considering the available scientific evidence concerning such hazards. Under the current HCS, the hazard determination provisions have definitions of hazard and the evaluator determines whether or not the data on a chemical meet those definitions. It is a performance-oriented approach that provides parameters for the evaluation, but not specific, detailed criteria. The hazard classification approach in the revised HCS is quite different. The revised HCS has specific criteria for each health and physical hazard, along with detailed instructions for hazard evaluation and determinations as to whether mixtures or substances are covered. It also establishes both hazard classes and hazard categories—for most of the effects; the classes are divided into categories that reflect the relative severity of the effect. The current HCS does not include categories for most of the health hazards covered, so this new approach provides additional information that can be related to the appropriate response to address the hazard. OSHA has included the general provisions for hazard classification in paragraph (d) of the revised rule, and added extensive appendixes (Appendixes A and B) that address the criteria for each health or physical effect.

Q. How will labels change under the revised Hazard Communication Standard?

A. Under the current Hazard Communication Standard (HCS), the label preparer must provide the identity of the chemical, and the appropriate hazard warnings. This may be done in a variety of ways, and the method to convey the information is left to the preparer. Under the revised HCS, once the hazard classification is completed, the standard specifies what information is to be provided for each hazard class and category. Labels will require the following elements:
  • Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the HCS.
  • Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards.
  • Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
  • Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical.

Thursday, December 20, 2012

New Hazard Communication Standard Q & A: Part 3

Q. Why must training be conducted prior to the compliance effective date?

A. OSHA is requiring that employees are trained on the new label elements (i.e., pictograms, hazard statements, precautionary statements, and signal words) and SDS format by December 1, 2013, while full compliance with the final rule will begin in 2015.  OSHA believes that American workplaces will soon begin to receive labels and SDSs that are consistent with the GHS, since many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDSs.  It is important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they will be familiar with them, understand how to use them, and access the information effectively.  For more information,

Q. Wat are the major changes to the Hazard Communication Standard?

A. The three major areas of change are in hazard classification, labels, and safety data sheets.
  • Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixture. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result.
  • Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category.  Precautionary statements must also be provided.
  • Safety Data Sheets: Will now have a specified 16-section format.
The GHS does not inlcude harmonized training provisions, but recognizes that training is essential to an effective hazard communication approach.  The revised Hazard Communication Standard (HCS) requires that workers be re-trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safety data sheets.

For a side-by-side comparison of the current HCS and the final revised HCS, National Safety Compliance has the #OSHA-HCS Hazard Communication Standard which includes this comparison.

Tuesday, December 11, 2012

New Hazard Communication Standard Q & A Part 2

Q. What is the phase-in period in the revised Hazard Communication Standard?

A. The table below summarizes the phase-in dates required under the revised Hazard Communication Standard (HCS):
Effective Completion Date
December 1, 2013
Train employees on the new label elements and safety data sheet (SDS) format.
June 1, 2015*
December 1, 2015
Compliance with all modified provisions of this final rule, except:
The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label
Chemical manufacturers, importers, distributors and employers
June 1, 2016
Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
Transition Period to the effective completion dates noted above
May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both
Chemical manufacturers, importers, distributors, and employers
*This date coincides with the EU implementation date for classification of mixtures
During the phase-in period, employers would be required to be in compliance with either the existing HCS or the revised HCS, or both. OSHA recognizes that hazard communication programs will go through a period of time where labels and SDSs under both standards will be present in the workplace. This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.

Friday, November 30, 2012

New Hazard Communication Standard Q & A Part 1

Q. What is the Globally Harmonized System?

A. The Globally Harmonized System (GHS) is an international approach to hazard communication, providing agreed criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets. The GHS was negotiated in a multi-year process by hazard communication experts from many different countries, international organizations, and stakeholder groups. It is based on major existing systems around the world, including OSHA's Hazard Communication Standard and the chemical classification and labeling systems of other US agencies.
The result of this negotiation process is the United Nations' document entitled "Globally Harmonized System of Classification and Labeling of Chemicals," commonly referred to as The Purple Book. This document provides harmonized classification criteria for health, physical, and environmental hazards of chemicals. It also includes standardized label elements that are assigned to these hazard classes and categories, and provide the appropriate signal words, pictograms, and hazard and precautionary statements to convey the hazards to users. A standardized order of information for safety data sheets is also provided. These recommendations can be used by regulatory authorities such as OSHA to establish mandatory requirements for hazard communication, but do not constitute a model regulation.

Q. Why did OSHA decide to modify the Hazard Communication Standard to adopt the GHS?

A. OSHA has modified the Hazard Communication Standard (HCS) to adopt the GHS to improve safety and health of workers through more effective communications on chemical hazards. Since it was first promulgated in 1983, the HCS has provided employers and employees extensive information about the chemicals in their workplaces. The original standard is performance-oriented, allowing chemical manufacturers and importers to convey information on labels and material safety data sheets in whatever format they choose. While the available information has been helpful in improving employee safety and health, a more standardized approach to classifying the hazards and conveying the information will be more effective, and provide further improvements in American workplaces. The GHS provides such a standardized approach, including detailed criteria for determining what hazardous effects a chemical poses, as well as standardized label elements assigned by hazard class and category. This will enhance both employer and worker comprehension of the hazards, which will help to ensure appropriate handling and safe use of workplace chemicals. In addition, the safety data sheet requirements establish an order of information that is standardized. The harmonized format of the safety data sheets will enable employers, workers, health professionals, and emergency responders to access the information more efficiently and effectively, thus increasing their utility.
Adoption of the GHS in the US and around the world will also help to improve information received from other countries—since the US is both a major importer and exporter of chemicals, American workers often see labels and safety data sheets from other countries. The diverse and sometimes conflicting national and international requirements can create confusion among those who seek to use hazard information effectively. For example, labels and safety data sheets may include symbols and hazard statements that are unfamiliar to readers or not well understood. Containers may be labeled with such a large volume of information that important statements are not easily recognized. Given the differences in hazard classification criteria, labels may also be incorrect when used in other countries. If countries around the world adopt the GHS, these problems will be minimized, and chemicals crossing borders will have consistent information, thus improving communication globally.

Tuesday, November 20, 2012

Hazard Communication Standard: Safety Data Sheets - Sections 15-16

Section 15: Regulatory Information (non-mandatory)
This section identifies the safety, health, and environmental regulations specific for the product
that is not indicated anywhere else on the SDS. The information may include:
• Any national and/or regional regulatory information of the chemical or mixtures (including any
OSHA, Department of Transportation, Environmental Protection Agency, or Consumer Product
Safety Commission regulations).
Section 16: Other Information
This section indicates when the SDS was prepared or when the last known revision was made.
The SDS may also state where the changes have been made to the previous version. You may
wish to contact the supplier for an explanation of the changes. Other useful information also may
be included here.

Employer Responsibilities

Employers must ensure that the SDSs are readily accessible to employees for all hazardous chemicals in their workplace. This may be done in many ways. For example, employers may keep the SDSs in a binder or on computers as long as the employees have immediate access to the information without leaving their work area when needed and a back-up is available for rapid access to the SDS in the case of a power outage or other emergency. Furthermore, employers may want to designate a person(s) responsible for obtaining and maintaining the SDSs. If the employer does not have an SDS, the employer or designated person(s) should contact the manufacturer to obtain one.

If you are needing safety training materials to ensure compliance with the new OSHA Hazard Communication Regulation 29 CFR 1910.1200, please contact National Safety Compliance, Inc. at 1-877-922-7233 or

Friday, November 9, 2012

Hazard Communication Standard: Safety Data Sheets - Sections 12-14

Section 12: Ecological Information (non-mandatory)
This section provides information to evaluate the environmental impact of the chemical(s) if it
were released to the environment. The information may include:
• Data from toxicity tests performed on aquatic and/or terrestrial organisms, where available
(e.g., acute or chronic aquatic toxicity data for fish, algae, crustaceans, and other plants; toxicity
data on birds, bees, plants).
• Whether there is a potential for the chemical to persist and degrade in the environment either
through biodegradation or other processes, such as oxidation or hydrolysis.
• Results of tests of bioaccumulation potential, making reference to the octanol-water partition
coefficient (Kow) and the bioconcentration factor (BCF), where available.
• The potential for a substance to move from the soil to the groundwater (indicate results from
adsorption studies or leaching studies).
• Other adverse effects (e.g., environmental fate, ozone layer depletion potential, photochemical
ozone creation potential, endocrine disrupting potential, and/or global warming potential).
Section 13: Disposal Considerations (non-mandatory)
This section provides guidance on proper disposal practices, recycling or reclamation of the
chemical(s) or its container, and safe handling practices. To minimize exposure, this section
should also refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS.
The information may include:
• Description of appropriate disposal containers to use.
• Recommendations of appropriate disposal methods to employ.
• Description of the physical and chemical properties that may affect disposal activities.
• Language discouraging sewage disposal.
• Any special precautions for landfills or incineration activities.
Section 14: Transport Information (non-mandatory)
This section provides guidance on classification information for shipping and transporting of
hazardous chemical(s) by road, air, rail, or sea. The information may include:
• UN number (i.e., four-figure identification number of the substance)2.
• UN proper shipping name2.
• Transport hazard class(es)2.
• Packing group number, if applicable, based on the degree of hazard2.
• Environmental hazards (e.g., identify if it is a marine pollutant according to the International
Maritime Dangerous Goods Code (IMDG Code)).
• Guidance on transport in bulk (according to Annex II of MARPOL 73/783 and the International
Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk
(International Bulk Chemical Code (IBC Code)).
• Any special precautions which an employee should be aware of or needs to comply with, in
connection with transport or conveyance either within or outside their premises (indicate
when information is not available).

Monday, November 5, 2012

Hazard Communication Standard: Safety Data Sheets - Sections 9-11

Section 9: Physical and Chemical Properties
This section identifies physical and chemical properties associated with the substance or mixture.
The minimum required information consists of:
• Appearance (physical state, color, etc.); • Upper/lower flammability or explosive limits;
• Odor; • Vapor pressure;
• Odor threshold; • Vapor density;
• pH; • Relative density;
• Melting point/freezing point; • Solubility(ies);
• Initial boiling point and boiling range; • Partition coefficient: n-octanol/water;
• Flash point; • Auto-ignition temperature;
• Evaporation rate; • Decomposition temperature; and
• Flammability (solid, gas); • Viscosity.
The SDS may not contain every item on the above list because information may not be relevant
or is not available. When this occurs, a notation to that effect must be made for that chemical
property. Manufacturers may also add other relevant properties, such as the dust deflagration
index (Kst) for combustible dust, used to evaluate a dust's explosive potential.
Section 10: Stability and Reactivity
This section describes the reactivity hazards of the chemical and the chemical stability
information. This section is broken into three parts: reactivity, chemical stability, and other.
The required information consists of:
• Description of the specific test data for the chemical(s). This data can be for a class or family
of the chemical if such data adequately represent the anticipated hazard of the chemical(s),
where available.
Chemical stability
• Indication of whether the chemical is stable or unstable under normal ambient temperature
and conditions while in storage and being handled.
• Description of any stabilizers that may be needed to maintain chemical stability.
• Indication of any safety issues that may arise should the product change in physical
• Indication of the possibility of hazardous reactions, including a statement whether the chemical
will react or polymerize, which could release excess pressure or heat, or create other hazardous
conditions. Also, a description of the conditions under which hazardous reactions may occur.
• List of all conditions that should be avoided (e.g., static discharge, shock, vibrations, or
environmental conditions that may lead to hazardous conditions).
• List of all classes of incompatible materials (e.g., classes of chemicals or specific substances)
with which the chemical could react to produce a hazardous situation.
• List of any known or anticipated hazardous decomposition products that could be produced
because of use, storage, or heating. (Hazardous combustion products should also be included
in Section 5 (Fire-Fighting Measures) of the SDS.)
Section 11: Toxicological Information
This section identifies toxicological and health effects information or indicates that such data
are not available. The required information consists of:
• Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact).
The SDS should indicate if the information is unknown.
• Description of the delayed, immediate, or chronic effects from short- and long-term exposure.
• The numerical measures of toxicity (e.g., acute toxicity estimates such as the LD50 (median
lethal dose)) - the estimated amount [of a substance] expected to kill 50% of test animals in a
single dose.
• Description of the symptoms. This description includes the symptoms associated with
exposure to the chemical including symptoms from the lowest to the most severe exposure.
• Indication of whether the chemical is listed in the National Toxicology Program (NTP)
Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the
International Agency for Research on Cancer (IARC) Monographs (latest editions) or found
to be a potential carcinogen by OSHA.

Tuesday, October 30, 2012

Hazard Communication Standard: Safety Data Sheets - Sections 5-8

Section 5: Fire-Fighting Measures
This section provides recommendations for fighting a fire caused by the chemical. The required information consists of:
  • Recommendations of suitable extinguishing equipment, and information about extinguishing equipment that is not appropriate for a particular situation.
  • Advice on specific hazards that develop from the chemical during the fire, such as any hazardous combustion products created when the chemical burns.
  • Recommendations on special protective equipment or precautions for firefighters.
Section 6: Accidental Release Measures
This section provides recommendations on the appropriate response to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people, properties, or the environment. It may also include recommendations distinguishing between responses for large and small spills where the spill volume has a significant impact on the hazard. The required information may consist of recommendations for:
  • Use of personal precautions (such as removal of ignition sources or providing sufficient ventilation) and protective equipment to prevent the contamination of skin, eyes, and clothing.
  • Emergency procedures, including instructions for evacuations, consulting experts when needed, and appropriate protective clothing.
  • Methods and materials used for containment (e.g., covering the drains and capping procedures).
  • Cleanup procedures (e.g., appropriate techniques for neutralization, decontamination, cleaning or vacuuming; adsorbent materials; and/or equipment required for containment/clean up)
Section 7: Handling and Storage
This section provides guidance on the safe handling practices and conditions for safe storage of chemicals. The required information consists of:
  • Precautions for safe handling, including recommendations for handling incompatible chemicals, minimizing the release of the chemical into the environment, and providing advice on general hygiene practices (e.g., eating, drinking, and smoking in work areas is prohibited).
  • Recommendations on the conditions for safe storage, including any incompatibilities. Provide advice on specific storage requirements (e.g., ventilation requirements)
Section 8: Exposure Controls/Personal Protection
This section indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure. The required information consists of:
  • OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available.
  • Appropriate engineering controls (e.g., use local exhaust ventilation, or use only in an enclosed system).
  • Recommendations for personal protective measures to prevent illness or injury from exposure to chemicals, such as personal protective equipment (PPE) (e.g., appropriate types of eye, face, skin or respiratory protection needed based on hazards and potential exposure).
  • Any special requirements for PPE, protective clothing or respirators (e.g., type of glove material, such as PVC or nitrile rubber gloves; and breakthrough time of the glove material).

Friday, October 19, 2012

Hazard Communication Standard: Safety Data Sheets - Sections 2-4

Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures (e.g., fire fighting). This information should be helpful to those that need to get the information quickly. Sections 9 through 11 and 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision. The SDS must also state that no applicable information was found when the preparer does not find relevant information for any required element.
The SDS must also contain Sections 12 through 15, to be consistent with the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS), but OSHA will not enforce the content of these sections because they concern matters handled by other agencies.
A description of all 16 sections of the SDS, along with their contents, will be presented in the next several posts:
Section 2: Hazard(s) Identification
This section identifies the hazards of the chemical presented on the SDS and the appropriate warning information associated with those hazards. The required information consists of:
  • The hazard classification of the chemical (e.g., flammable liquid, category1).
  • Signal word.
  • Hazard statement(s).
  • Pictograms (the pictograms or hazard symbols may be presented as graphical reproductions of the symbols in black and white or be a description of the name of the symbol (e.g., skull and crossbones, flame).
  • Precautionary statement(s).
  • Description of any hazards not otherwise classified.
  • For a mixture that contains an ingredient(s) with unknown toxicity, a statement describing how much (percentage) of the mixture consists of ingredient(s) with unknown acute toxicity. Please note that this is a total percentage of the mixture and not tied to the individual ingredient(s).
Section 3: Composition/Information on Ingredients
This section identifies the ingredient(s) contained in the product indicated on the SDS, including impurities and stabilizing additives. This section includes information on substances, mixtures, and all chemicals where a trade secret is claimed. The required information consists of:
  • Chemical name.
  • Common name and synonyms.
  • Chemical Abstracts Service (CAS) number and other unique identifiers.
  • Impurities and stabilizing additives, which are themselves classified and which contribute to the classification of the chemical.
  • Same information required for substances.
  • The chemical name and concentration (i.e., exact percentage) of all ingredients which are classified as health hazards and are:
    • Present above their cut-off/concentration limits or
    • Present a health risk below the cut-off/concentration limits.
  • The concentration (exact percentages) of each ingredient must be specified except concentration ranges may be used in the following situations:
    • A trade secret claim is made,
    • There is batch-to-batch variation, or
    • The SDS is used for a group of substantially similar mixtures.
Chemicals where a trade secret is claimed
  • A statement that the specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a trade secret is required.
Section 4: First-Aid Measures
This section describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical. The required information consists of:
  • Necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact, and ingestion).
  • Description of the most important symptoms or effects, and any symptoms that are acute or delayed.
  • Recommendations for immediate medical care and special treatment needed, when necessary.

To be continued....
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Friday, October 12, 2012

Hazard Communication Standard: Safety Data Sheets - Section 1

The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)), revised in 2012, requires that the chemical manufacturer, distributor, or importer provide Safety Data Sheets (SDSs) (formerly MSDSs or Material Safety Data Sheets) for each hazardous chemical to downstream users to communicate information on these hazards. The information contained in the SDS is largely the same as the MSDS, except now the SDSs are required to be presented in a consistent user-friendly, 16-section format. These next several posts will provide guidance to help workers who handle hazardous chemicals to become familiar with the format and understand the contents of the SDSs.
The SDS includes information such as the properties of each chemical; the physical, health, and environmental health hazards; protective measures; and safety precautions for handling, storing, and transporting the chemical. The information contained in the SDS must be in English (although it may be in other languages as well). In addition, OSHA requires that SDS preparers provide specific minimum information as detailed in Appendix D of 29 CFR 1910.1200. The SDS preparers may also include additional information in various section(s).
Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures (e.g., fire fighting). This information should be helpful to those that need to get the information quickly. Sections 9 through 11 and 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision. The SDS must also state that no applicable information was found when the preparer does not find relevant information for any required element.
The SDS must also contain Sections 12 through 15, to be consistent with the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS), but OSHA will not enforce the content of these sections because they concern matters handled by other agencies.
A description of all 16 sections of the SDS, along with their contents, will be presented in the next several posts:
Section 1: Identification
This section identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier. The required information consists of:
  • Product identifier used on the label and any other common names or synonyms by which the substance is known.
  • Name, address, phone number of the manufacturer, importer, or other responsible party, and emergency phone number.
  • Recommended use of the chemical (e.g., a brief description of what it actually does, such as flame retardant) and any restrictions on use (including recommendations given by the supplier). 1
To be continued...

For more information visit

Tuesday, July 17, 2012

Safety Data Sheets for the New Hazcom Standard

The Hazard Communication Standard (HCS) requires chemical manufacturers, distributors, or importers to provide Safety Data Sheets (SDSs) (formerly known as Material Safety Data Sheets or MSDSs) to communicate the hazards of hazardous chemical products. As of June 1, 2015, the HCS will require new SDSs to be in a uniform format, and include the section numbers, the headings, and associated information under the headings below:
Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.
Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.
Section 4, First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.
Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.
Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.
Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.
Section 8, Exposure controls/personal protection lists OSHA's Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
Section 9, Physical and chemical properties lists the chemical's characteristics.
Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.
Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
Section 12, Ecological information*
Section 13, Disposal considerations*
Section 14, Transport information*
Section 15, Regulatory information*
Section 16, Other information, includes the date of preparation or last revision.
*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)).
Employers must ensure that SDSs are readily accessible to employees.
See Appendix D of 1910.1200 for a detailed description of SDS contents.

National Safety Compliance has developed new products to ensure companies have the resources to comply with this new Hazard Communication Standard.

Wednesday, May 9, 2012

GHS/Hazard Communication In-Depth Training Kit

New changes to the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard are bringing the United States into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), further improving safety and health protections for America's workers. Building on the success of OSHA's current Hazard Communication Standard, the GHS is expected to prevent injuries and illnesses, save lives and improve trade conditions for chemical manufacturers. The Hazard Communication Standard in 1983 gave the workers the 'right to know,' but the new Globally Harmonized System gives workers the 'right to understand.'

The new hazard communication standard still requires chemical manufacturers and importers to evaluate the chemicals they produce or import and provide hazard information to employers and workers by putting labels on containers and preparing safety data sheets. However, the old standard allowed chemical manufacturers and importers to convey hazard information on labels and material safety data sheets in whatever format they chose. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets. 

Major changes to the Hazard Communication Standard:
  • Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
  • Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
  • Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
  • Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.
What you need to do:
  • Chemical users: Continue to update safety data sheets when new ones become available, provide training on the new label elements and update hazard communication programs if new hazards are identified.
  • Chemical Producers: Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets.
To help employers to comply with these new regulations, National Safety Compliance has produced updated products that are designed specifically for this new Hazard Communication Standard. All products are now available to ship. For more information please visit www.ghs-hazard-communication.com

Friday, April 6, 2012

Final Rule Published in the Federal Register

The long awaited major change to the 29 CFR 1910.1200 OSHA Hazard Communication Standard has arrived. It was approved by the OMB and has been put in the Federal Register.

In this final rule, OSHA is modifying its Hazard Communication Standard (HCS) to conform to the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). OSHA has determined that the modifications will significantly reduce costs and burdens while also improving the quality and consistency of information provided to employers and employees regarding chemical hazards and associated protective measures. Consistent with the requirements of Executive Order 13563, which calls for assessment and, where appropriate, modification and improvement of existing rules, the Agency has concluded this improved information will enhance the effectiveness of the HCS in ensuring that employees are apprised of the chemical hazards to which they may be exposed, and in reducing the incidence of chemical-related occupational illnesses and injuries.

The modifications to the standard include revised criteria for classification of chemical hazards; revised labeling provisions that include requirements for use of standardized signal words, pictograms, hazard statements, and precautionary statements; a specified format for safety data sheets; and related revisions to definitions of terms used in the standard, and requirements for employee training on labels and safety data sheets. OSHA is also modifying provisions of other standards, including standards for flammable and combustible liquids, process safety management, and most substance-specific health standards, to ensure consistency with the modified HCS requirements. The consequences of these modifications will be to improve safety, to facilitate global harmonization of standards, and to produce hundreds of millions of dollars in annual savings.

In an attempt to help employers comply with this newly revised Hazard Communication Standard, NSC has produced 3 new DVD Training Programs: Hazard Communication Safety, GHS-Safety Data Sheets Training, & GHS-Chemical Labels Training. These have been packaged together for significant savings.

Friday, February 24, 2012

OMB Review of the Hazard Communication Standard alignment with GHS Complete

As mentioned previously, the Office of Management and Budget (OMB) placed the Hazard Communication Standard (HCS) in extended review on January 24, 2012. As of February 21, 2012 the OMB has completed its review of the proposed Final Rule to align the HCS with the GHS. This proposed change will affect over 40 million workers in the U.S. who are exposed to hazardous chemicals.

The main areas that these changes focus are the following:
  • Employee training
  • Safety Data Sheets (SDS)
  • Chemical labeling

National Safety Compliance will be releasing a training package specifically to assist employers in complying with the revised hazard communication standard in aligning with GHS. The training package will consist of 3 newly produced complete training kits with DVD and additional printable material to ensure you can train all your affected employees.

Monday, February 20, 2012

2013 Department of Labor Budget Q & A February 13, 2012

On February 13th several leaders of the Department of Labor held a Questions & Answers session regarding the 2013 Budget. The following are a few highlights specific to OSHA and safety in the workplace.

When is the final rule regarding GHS in the US expected to be adopted?

David Michaels, Assistant Secretary of OSHA responds:
Thank you for your interest in OSHA’s Hazard Communication Standard (HCS). We expect this rule to be published soon. This is a very important rule, which OSHA looks forward to publishing shortly. This rulemaking will align OSHA’s HCS with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), which was developed by the United Nations. As discussed in the proposal, this rule will establish a uniform system of labeling and layout for safety data sheets. The training required in the current HCS will be retained.

While the DOL's Budget brief pints out a drive to boost small businesses, will OSHA change its attitude from "gotcha" to perhaps take a softer approach, such as giving companies a grace period, or levying fines based on employee count as opposed to fixed numbers--so as not to close down small businesses?

David Michaels responds:
We always try to work with small businesses to protect employees and our enforcement policies include a reduction of fines, and OSHA also offers free on-site consultation specifically targeted to small businesses.

The budget says combustible dust and beryllium NPRMs will come out in FY 2013. If that's the plan, why were those items placed on long-term actions in the most recent Regulatory Agenda?

David Michaels responds:
For combustible dust and beryllium the next major action planned will occur after the period covered by the current regulatory agenda.

The budget request calls for a $4.9 million increase for OSHA's whistleblower program, and a $3.2 million decrease for its federal compliance assistance program. Can you comment on these proposals?

David Michaels responds:
Although our compliance assistance activities are divided into three budget categories, we view it as a whole, and overall, FY 2013 compliance assistance is 2% above FY 2011. Because of the severe budget constraints we’re facing throughout the federal government, we are tightening our belts in a number of areas and we had to choose among many priorities. In this case, our priority is maintaining the 2012 increases for small business assistance through our state consultation program.

Could you elaborate on this line in OSHA's budget? "savings of $2,482,000 and 33 FTE due to reduced federal compliance assistance activity from the consolidation of personnel in geographically dense regions."

David Michaels responds:
OSHA has a compliance assistance specialist in every one of its more than 70 area offices. Many of these are situated very close to each other. In order to save money and streamline resources we will be asking some compliance assistance staff to cover a slightly larger area.

How can around 1,000 OSHA complianceofficers effectively inspect and regulate over 7,000,000 workplaces (conservative estimate)? What is the long term plan to level the playing field, the math just does not compute?

David Michaels responds:
First of all 27 state plans have an additional 1,000 inspectors to cover about half the states. OSHA uses an inspection targeting formula, national and local emphasis programs, partnerships and cooperative programs like VPP to focus attention to where the highest hazards exist.

How does this budget effect OSHA? Will you be hiring more Compliance Officers?

David Michaels responds:
Under this budget, OSHA will not be hiring more compliance officers however the budget requests funding to hire 37 new whistleblower investigators.

How will the 2013 Budget Proposal effect the State Plan States?

David Michaels responds:
The FY 2013 budget request for State Plan States maintains the level of funding provided in FY 2012.

I would like to work for OSHA as an Inspector. What are the requirements needed for training?

David Michaels responds:
There are different requirements for industrial hygiene or safety specialist. You can go to to see the job postings. Good luck!

With the reduction of 33 OSHA Compliance Assistant how will OSHA service our vulnerable workforce?

David Michaels responds:
Good question. OSHA is maintaining its emphasis on reaching out to vulnerable and hard to reach workers in high risk jobs, as well as small businesses. OSHA will continue its award-winning outreach efforts around such hazards as heat exposure, hearing protection and fall prevention. The cuts outlined in our FY 2013 budget request focus primarily on employer compliance assistance.

At 2:50 David Michaels indicated that OSHA would continue work on, among other things, injury and illness prevention plans. Does the 2013 Budget contain specific funding for I2P2 or is this referenced work to be done without specific funding?

David Michaels responds:
No, there is no standard-specific funding in the FY 2013 budget. OSHA's standards budget request contained $1 million increase for overall standards work.

Do we know which OSHA regional offices will be eliminated (e.g., will it be Boston or New York)? Also, will OSHA institute sub-regional offices to serve the areas where the offices are being consolidated?

David Michaels responds:
No, there are no specific plans on how the regional consolidations will be implemented. OSHA will maintain offices as needed to ensure that safety and health coverage is maintained.

Tuesday, January 24, 2012

HCS Update to align with GHS

The Office of Management and Budget (OMB) has Extended Review of the Final Rule regarding the major revision of the Hazard Communication Standard (HCS) to align with the Globally Harmonized System. This Final Rule was received on October 25, 2011 for the 90-Review by the OMB. As of January 24, 2012 (the 90-day deadline), the OMB has extended the review until further notice.

You may visit us online to place a preorder for any 2012 HCS OSHA compliance products.

DOL/OSHA RIN: 1218-AC20 Publication ID: Spring 2011
Title: Hazard Communication
Abstract: OSHA's Hazard Communication Standard (HCS) requires chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import, and prepare labels and material safety data sheets to convey the hazards and associated protective measures to users of the chemicals. All employers with hazardous chemicals in their workplaces are required to have a hazard communication program, including labels on containers, material safety data sheets (MSDS), and training for employees. Within the United States (U.S.), there are other Federal agencies that also have requirements for classification and labeling of chemicals at different stages of the life cycle. Internationally, there are a number of countries that have developed similar laws that require information about chemicals to be prepared and transmitted to affected parties. These laws vary with regard to the scope of substances covered, definitions of hazards, the specificity of requirements (e.g., specification of a format for MSDSs), and the use of symbols and pictograms. The inconsistencies between the various laws are substantial enough that different labels and safety data sheets must often be used for the same product when it is marketed in different nations. The diverse and sometimes conflicting national and international requirements can create confusion among those who seek to use hazard information. Labels and safety data sheets may include symbols and hazard statements that are unfamiliar to readers or not well understood. Containers may be labeled with such a large volume of information that important statements are not easily recognized. Development of multiple sets of labels and safety data sheets is a major compliance burden for chemical manufacturers, distributors, and transporters involved in international trade. Small businesses may have particular difficulty in coping with the complexities and costs involved. As a result of this situation, and in recognition of the extensive international trade in chemicals, there has been a long-standing effort to harmonize these requirements and develop a system that can be used around the world. In 2003, the United Nations adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Countries are now adopting the GHS into their national regulatory systems. OSHA published the NPRM on September 30, 2009 and held public hearings in Washington, DC and Pittsburgh, PA in March 2010. The record closed on June 1, 2010. OSHA is scheduled to publish the final rule in August 2011.
Agency: Department of Labor(DOL) Priority: Economically Significant
RIN Status: Previously published in the Unified Agenda Agenda Stage of Rulemaking: Final Rule Stage
Major: Yes Unfunded Mandates: Private Sector
CFR Citation: 29 CFR 1910.1200; 29 CFR 1915.1200; 29 CFR 1917.28; 29 CFR 1918.90; 29 CFR 1926.59; 29 CFR 1928.21
Legal Authority: 29 USC 655(b); 29 USC 657
Legal Deadline: None
Anticipated Costs and Benefits:
The estimates of the costs and benefits are still under development.
OSHA's risk analysis is under development.

Friday, January 13, 2012

Hazcom Standard Clarification

(1) Can chemical manufacturers who sell their products, in part, through company-owned and operated retail and wholesale outlets avail themselves of the provisions in the Hazard Communication Standard (HCS) permitting the distribution of Material Safety Data Sheets (MSDS) on request to walk-up retail customers?

(2) Can chemical manufacturers who operate as wholesale distributors serving industrial and construction trades people, as described in subparagraphs (v) and (vi), and who also own and operate "commercial" stores, take the same position (i.e., distribute MSDS directly upon request)? Commercial stores may serve walk-up trade; consumers as well as businesses may purchase products at such outlets.

Standard Interpretation

For hazard communication purposes, the standard allows a business entity functioning as the chemical manufacturer to meet the standard's requirements as the chemical manufacturer, and also when distributing the product in a retail store, as the retail distributor, meet the standard's requirements for retail distributors. A retail distributor is one that primarily sells to the general public for personal or household use. The intent of the provision, (g)(7)(iii), was to reduce the burden on retail distributors because they typically do not sell to commercial customers.

We must disagree with your statement " is also acceptable, with respect to products manufactured by another manufacturer, for these retail distributors to refer persons requesting an MSDS to the other manufacturer." When an employer with a commercial account at a retail distributor requests an MSDS, the MSDS must be provided with the purchase by the retail distributor. In this case, the retail distributor cannot refer the customer to the chemical manufacturer for the MSDS. The HCS (1910.1200(g)(7)(v)) does allow a retail distributor, who does not have commercial accounts, to refer the employer to the chemical manufacturer, importer, or distributor for the sheet.

OSHA also allows wholesale distributors to provide an MSDS on request in over-the-counter sales operations as described under paragraph (g)(7)(iv) of the standard. This provision is for over-the-counter type operations only. As stated in the preamble to the final rule (59 FR 6162), "wholesale distributors that have over-the-counter sales should be permitted to provide MSDSs on request as their operations are similar to those of concern in retail establishments." Consequently, the commercial stores (wholesale distributors) mentioned in your letter could choose the alternative compliance strategy in 1910.1200(g)(7)(iv).

Tuesday, January 10, 2012

Do you know what is in your chemicals

You must know what is in your chemicals to be sure you’re taking the necessary steps to keep your employees safe.

You must be sure you are compliant with all of the local, state, federal and international regulations with jurisdiction over your facility?

And when you think of the word ‘chemical’, are you only thinking about pure chemical substances such as mercury and salt? You must also include all of your products and blends that are comprised of chemicals. For example, paint is notorious for having blends of dozens of chemicals.

Hazard communication has never been more important to the health of your employees or your company. Today that means understanding the toxic nature of your chemical and product inventory at the ingredient level. If not properly understood, every chemical or chemical blend in your inventory has the potential to create safety and compliance issues. With the new Globally Harmonized System of Classification final rule just around the corner, employers must ensure proper training of employees is in place.

National Safety Compliance has several items to assist companies in complying with OSHA Regulations 29 CFR 1910.1200 Hazard Communication Standard. NSC has also provided a web site where you can preorder various compliance items to make sure you are in alignment with the new GHS.