Wednesday, December 11, 2013

Mandatory Training Deadline

As we look to the new year we remember the significant change to the OSHA Hazard Communication Standard (1910.1200).  The first of several effective dates has come and gone.  Employers were to ensure their employees were trained on the new chemical labe elements and the safety data sheet (SDS) format.  If you have missed this deadline it is not too late to act.  National Safety Compliance has produced a GHS / Hazcom In-Depth Training Kit to ensure your compliance with these new OSHA Regulations.

Effective Dates

The table below summarizes the phase-in dates required under the revised Hazard Communication Standard (HCS):
Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format. Employers
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. Employers
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

Wednesday, November 13, 2013

Hazard Communication Standard Labels

Hazard Communication Standard Labels

OSHA has updated the requirements for labeliing of hazardous chemicals under its Hazard Communication Standard (HCS). As of June 1, 2015, all labels will be required to have pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification. A sample revised HCS label, identifying the required label elements, is shown on the right. Supplemental information can also be provided on the label as needed.

Tuesday, November 5, 2013

Permissible Exposure Limits – Annotated Tables

OSHA recognizes that many of its permissible exposure limits (PELs) are outdated and inadequate for ensuring protection of worker health. Most of OSHA’s PELs were issued shortly after adoption of the Occupational Safety and Health (OSH) Act in 1970, and have not been updated since that time. Section 6(a) of the OSH Act granted the Agency the authority to adopt existing Federal standards or national consensus standards as enforceable OSHA standards. Most of the PELs contained in the Z-Tables of 29 CFR 1910.1000 were adopted from the Walsh-Healy Public Contracts Act as existing Federal standards for general industry. These in turn had been adopted from the 1968 Threshold Limit Values (TLVs®) of the American Conference of Governmental Industrial Hygienists (ACGIH®). Some consensus standards from the American Standards Association were also adopted at that time, following the 6(a) procedures.
Comparable PELs were adopted for shipyards (29 CFR 1915.1000) and construction (29 CFR 1926.55).

Since 1970, OSHA promulgated complete 6(b) standards including new PELs for 16 agents, and standards without PELs for 13 carcinogens.

Industrial experience, new developments in technology, and scientific data clearly indicate that in many instances these adopted limits are not sufficiently protective of worker health. This has been demonstrated by the reduction in allowable exposure limits recommended by many technical, professional, industrial, and government organizations, both inside and outside the United States. Many large industrial organizations have felt obligated to supplement the existing OSHA PELs with their own internal corporate guidelines. OSHA’s Hazard Communication standard (1910. 1200 Appendix D) requires that safety data sheets list not only the relevant OSHA PEL but also the ACGIH® TLV® and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet.

To provide employers, workers, and other interested parties with a list of alternate occupational exposure limits that may serve to better protect workers, OSHA has annotated the existing Z-Tables with other selected occupational exposure limits. OSHA has chosen to present a side-by-side table with the Cal/OSHA PELs, the NIOSH Recommended Exposure Limits (RELs) and the ACGIH® TLVs®s. The tables list air concentration limits, but do not include notations for skin absorption or sensitization.

OSHA’s mandatory PELs in the Z-Tables remain in effect. However, OSHA recommends that employers consider using the alternative occupational exposure limits because the Agency believes that exposures above some of these alternative occupational exposure limits may be hazardous to workers, even when the exposure levels are in compliance with the relevant PELs.

  • California Division of Occupational Safety and Health (Cal/OSHA) Permissible Exposure Limits (PELs). Cal/OSHA has established an extensive list of PELs (Cal/OSHA AC-1 Table) that are enforced in workplaces under its jurisdiction. Cal/OSHA PELs are promulgated under statutory requirements for risk and feasibility that are no less protective than the OSH Act. Though not enforceable in establishments outside of Cal/OSHA’s jurisdiction, the PELs can provide information on acceptable levels of chemicals in the workplace. Of all the states that have OSHA-approved State Plans, California has the most extensive list of OELs.
  • National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limits (RELs). NIOSH RELs are authoritative Federal agency recommendations established according to the legislative mandate for NIOSH to recommend standards to OSHA. RELs are intended to limit exposure to hazardous substances in workplace air to protect worker health. In developing RELs and other recommendations to protect worker health, NIOSH evaluates all available medical, biological, engineering, chemical, and trade information relevant to the hazard. NIOSH transmits its recommendations to OSHA for use in developing legally enforceable standards. NIOSH also publishes its recommendations in publicly available sources such as the NIOSH Pocket Guide to Chemical Hazards, Criteria Documents, Current Intelligence Bulletins, Alerts, Special Hazard Reviews, Occupational Hazard Assessments, and Technical Guidelines.
  • ACGIH® Threshold Limit Values (TLVs®) and Biological Exposure Indices (BEIs®). ACGIH® is a private, not-for-profit, nongovernmental corporation. It is not a standards setting body. ACGIH® is a scientific association that develops recommendations or guidelines to assist in the control of occupational health hazards. TLVs® and BEIs® are health-based values and are not intended to be used as legal standards.
    Threshold Limit Values (TLVs®) refer to airborne concentrations of chemical substances and represent conditions under which it is believed that nearly all workers may be repeatedly exposed, day after day, over a working lifetime, without adverse effects.
    Biological Exposure Indices (BEIs®) are guidance values for assessing biological monitoring results – concentrations of chemicals in biological media (e.g., blood, urine). BEIs® represent the levels of determinants that are most likely to be observed in specimens collected from healthy workers who have been exposed to chemicals in the same extent as workers with inhalation exposure at the TLV®.
    Since ACGIH® TLVs® and BEIs® are based solely on health factors, there is no consideration given to economic or technical feasibility. ACGIH® does not believe that TLVs® and BEIs® should be adopted as standards without an analysis of other factors necessary to make appropriate risk management decisions (e.g., control options, technical and economic factors, etc.).

Monday, October 28, 2013

News Release: New resources regarding Hazardous Chemicals

Trade News Release Banner Image

OSHA Statement: 13-2026-NAT
Date: Oct. 24, 2013
Contact: Jesse Lawder     Adriano Llosa
Phone: 202-693-4659     202-693-4686
OSHA releases new resources to better protect workers
from hazardous chemicals

WASHINGTON – Each year in the United States, tens of thousands of workers are made sick or die from occupational exposures to the thousands of hazardous chemicals that are used in workplaces every day. The U.S. Department of Labor's Occupational Safety and Health Administration today launched two new web resources to assist companies with keeping their workers safe.

While many chemicals are suspected of being harmful, OSHA's exposure standards are out-of-date and inadequately protective for the small number of chemicals that are regulated in the workplace. The first resource OSHA has created is a toolkit to identify safer chemicals that can be used in place of more hazardous ones. This toolkit walks employers and workers step-by-step through information, methods, tools and guidance to either eliminate hazardous chemicals or make informed substitution decisions in the workplace by finding a safer chemical, material, product or process.

"We know that the most efficient and effective way to protect workers from hazardous chemicals is by eliminating or replacing those chemicals with safer alternatives whenever possible," said Dr. David Michaels, assistant secretary of labor for occupational safety and health. 

OSHA also created another new web resource: the Annotated Permissible Exposure Limits, or annotated PEL tables, which will enable employers to voluntarily adopt newer, more protective workplace exposure limits. OSHA's PELs set mandatory limits on the amount or concentration of a substance in the air to protect workers against the health effects of certain hazardous chemicals; and OSHA will continue to enforce those mandatory PELs. Since OSHA's adoption of the majority of its PELs more than 40 years ago, new scientific data, industrial experience and developments in technology clearly indicate that in many instances these mandatory limits are not sufficiently protective of workers' health. 

"There is no question that many of OSHA's chemical standards are not adequately protective," Michaels said. "I advise employers, who want to ensure that their workplaces are safe, to utilize the occupational exposure limits on these annotated tables, since simply complying with OSHA's antiquated PELs will not guarantee that workers will be safe."

The annotated PEL tables provide a side-by-side comparison of OSHA PELs for general industry to the California Division of Occupational Safety and Health PELs, National Institute for Occupational Safety and Health recommended exposure limits, and American Conference of Governmental Industrial Hygienist threshold limit values. They offer an easily accessible reference source for up-to-date workplace exposure limits.

Tuesday, October 22, 2013

MSDS or SDS in December 2013?

Many employers are anticipating the mandatory, OSHA regulated change from the old Material Safety Data Sheet format to the new required GHS-aligned Safety Data Sheet format within the next few months.  This is not a very accurate portrayal of the transition ahead.  Employers are required to ensure their employees are trained regarding the new Hazard Communication Standard (HCS), including the new format of the Safety Data Sheet (SDS).  However, the date by which all chemical manufacturers are to have all sheets switched to the new format is not until June 1, 2015.  In the mean time, managing MSDS/SDS is going to be a nightmare.  Each employer will possibly have a mixture of the old format with the new format.  Not only will employers need to handle the 2 different formats, but as manufacturers continue to transition (deadline June 1, 2015), they are releasing sheets that are neither the old format or the new format.  They commonly will have a mixture of data from the old Material Safety Data Sheet, along with elements in the Safety Data Sheet (GHS-aligned) format.

Tuesday, October 15, 2013

Webinar by Compli

As we continue to approach the December 1, 2013 training deadline, employers must ensure their employees are properly trained for the significant changes made to the OSHA Hazard Communication Standard. is hosting a webinar on November 6, 2013 to help employers prepare for the Globally Harmonized System (GHS) compliant OSHA regulations.

Globally Harmonized System (GHS) - Are You Ready? 
Wednesday, November 6, 2013
Successful businesses have strong worker safety and OSHA compliance programs, but regulatory changes can challenge even the best companies. Under the new OSHA Hazard Communication Standard (HAZCOM), employers must provide training for workers to align with the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals, by December 1, 2013. What does this mean for your business? Are you compliant and safe?
Join ComplĂ­ and Kris Bonner, Principal Consultant with the EH&S consulting firm EORM, as we discuss what you will need to know to keep your business compliant and successful under the new OSHA GHS requirements.

Learning Objectives:
  • Find out what GHS is and why it was adopted
  • Learn about the classification of hazards and label requirements
  • Understand how to take chemical inventory & safety data sheets
  • Identify the key differences between State and Federal obligations
  • And more...
This Webinar will conclude with a live Q&A Session, so please have your questions ready.
*Note: Not a toll-free phone number

Wednesday, October 9, 2013

Interpretation of OSHA's Hazard Communication Standard for Combustible Dust

March 25, 2013

Re: Request for Interpretation of OSHA’s Hazard Communication Standard for Combustible Dust

Dear Mr. S***:

This is in response to your inquiry on behalf of the American Chemistry Council concerning how OSHA's March 26, 2012, revisions to its Hazard Communication Standard (HCS 2012) apply to combustible dust. Below I summarize each of your questions and provide our response to it.
  1. Hazard Statement. Under HCS 2012, chemicals that have been classified as combustible dusts must include the following hazard statement on their labels and safety data sheets (SDSs): "May form combustible dust concentrations in air." You ask whether, for chemicals that pose a combustible dust hazard when processed but not in the current shipped form, the responsible party1 may include additional language with the hazard statement. You propose two alternatives (indicated by italics):

    1. If converted to small particles during further processing, handling, or by other means, may form combustible dust concentrations in air.
    2. If small particles are generated during further processing, handling or by other means, may form combustible dust concentrations in air.
  2. OSHA RESPONSE: Paragraph C.3.1 of Appendix C to HCS 2012 states that the responsible party may provide additional information on a label "when it provides further detail and does not contradict or cast doubt on the validity of the standardized hazard information." OSHA views either of the alternatives you propose as falling within C.3.1 because they provide additional detail and do not contradict or cast doubt on the validity of the required hazard statement where the chemical does not present a combustible dust hazard in the form shipped. Similarly, the required elements listed in Appendix D for SDSs are the minimum information required and OSHA believes that additional information that satisfies C.3.1 may be included in Section 2 of the SDS if the additional information concerns hazard identification. Therefore, it would be acceptable to OSHA if responsible parties included either alternative in conjunction with the required hazard statement on labels and SDSs for such chemicals.

  3. Safety Data Sheets. Your two questions on SDSs also pertain to chemicals that are not a combustible dust in the form shipped but that may present a combustible dust hazard under normal conditions of use due to the way they are processed by a downstream user.

    1. You ask whether SDSs may include additional information and explanatory statements, and provided us with a hypothetical SDS containing such information. In general, OSHA does not offer letters of interpretation passing on the adequacy of particular SDSs because OSHA does not possess the manufacturers' knowledge about the hazards and use of the product. OSHA is not making a determination on the adequacy of the hypothetical SDS you provided, however, there are a few general issues presented that OSHA can provide an interpretation on.

      In Section 2 (Hazard Identification) of the SDS, you propose listing:

      1. "OSHA Hazard Category: Combustible Dust";
      2. "GHS Hazard Categories: Not classified";
      3. "OSHA label elements," including the fact that there is no pictogram, a signal word of "Warning," the hazard statement for combustible dust with the additional language noted above in 1.b., and certain precautionary statements about the combustible dust hazard;
      4. Information about any hazards not otherwise classified presented by the product; and
      5. HMIS and NFPA ratings for the product.
    2. OSHA RESPONSE: For purposes of this response, OSHA assumes that the SDS is for a chemical that poses a combustible dust hazard arising from downstream processing, but not in the shipped form, and that it presents no other HCS-covered hazards. In such cases, OSHA views the language in items (i) and (ii) above as being consistent with the requirements of Section 2(a) of Appendix D of HCS 2012.
      For item (iii), it is consistent with Section 2(b) of Appendix D to note that there is no pictogram" and to use the same additional language that appears on the label in conjunction with the required hazard warning language. The signal word "Warning" is also required. OSHA has no required precautionary statements for combustible dust, and therefore none are required in Section 2 of the SDS. Responsible parties may add their own precautionary statements to Section 2 so long as they are relevant and do not contradict or cast doubt on the validity of the other information in the SDS.
      The information referenced in item (iv) is required by Section 2(c) of Appendix D. On item (v), responsible parties may include HMIS and NFPA ratings in Section 2 of the SDS as long as they do not contradict or cast doubt on the HCS 2012 classification.
    3. Appendix C.4.30, footnote 2, states that where chemicals are not shipped in a dust form but may be processed under normal conditions of use by a downstream user in such a way as to create a combustible dust hazard, the responsible party may provide labels in accordance with 1910.1200(f)(4). That provision allows labels to be provided once to downstream users, either with the initial shipment or with the SDS for the chemical. You ask whether it would be acceptable to provide the (f)(4) label by printing it at the top of the first page of the SDS.
  4. OSHA RESPONSE: Yes, where (f)(4) applies, it is acceptable to provide the label by printing it at the top of the first page of the SDS. Note that the (f)(4) partial labeling exemption is available only for chemicals that present no HCS 2012-covered hazard in the form shipped. If a chemical presents an HCS 2012-covered hazard in the form shipped, for example a health hazard, the (f)(4) exemption would not apply even if the chemical presents a combustible dust hazard only after processing in the normal conditions of use.
  5. Labels on shipped containers. You have several questions concerning the labeling of chemicals presenting a combustible dust hazard.
    1. You ask whether it is acceptable for a shipped container containing a chemical that presents a combustible dust hazard to include an HMIS label in addition to the information required by 1910.1200(f)(1) and C.4.30.

      OSHA RESPONSE: Yes, so long as the ratings in the HMIS label do not contradict or cast doubt on the validity of label information required by HCS 2012 (C.3.1) or impede the user's ability to identify the information required by HCS 2012 (C.3.2).
    2. You also ask whether, when (f)(4) applies, the shipped container may bear a label containing only product identifiers, manufacturer name and address, and an emergency phone number. In addition, you ask whether, in addition to the information contained in the previous sentence, the container may also bear an HMIS label.

      OSHA RESPONSE: Yes, where (f)(4) applies and the HCS 2012 label has already been provided by other means, either of these alternatives are acceptable. In fact, OSHA encourages responsible parties to provide product identifier and contact information on each shipped product whenever they take advantage of the (f)(4) option. However, any information that appears may not contradict or cast doubt on the validity of the label information required by HCS 2012.
    3. Finally, you ask whether, under footnote 2 to C.4.30, the (f)(4) partial labeling exemption is available for a liquid that under normal conditions of use may turn into a solid form that presents a combustible dust hazard.
  6. OSHA RESPONSE: Yes, assuming the liquid in its shipped form presents no other hazards that would be classified under HCS 2012. As discussed in 2.b, if the liquid presents any other hazards, then (f)(4) would not apply. Again, OSHA encourages responsible parties to provide the product identifier and contact information on each such product.
  7. Workplace labels. This issue concerns the workplace labeling requirements under 1910.1200(f)(6) in situations where a chemical is not a combustible dust in the form shipped, but may become one when processed by a downstream user. Your first question is whether, when the responsible party provides the label in accordance with (f)(4), the downstream user must label any containers containing the chemical in the workplace. Second, you ask if whether, once the product is processed in a way to create the combustible dust hazard, the employer may warn of the hazard by labeling the area (consistent with 1910.1200(f)(7)) where the processing of the materials generates sufficient dust to present a combustible dust hazard in lieu of affixing an (f)(1) label to each container. Finally, if the materials are not in a "container," as defined in 1910.1200(c), but the processing of the materials (e.g., the sawing of PVC pipes or lumber) is such that it may create a potential combustible dust hazard, you ask whether the employer may warn of the hazard by labeling the work areas (consistent with 1910.1200(f)(7)) where the processing of the materials takes place in lieu of affixing an (f)(6) label on each piece of piping or lumber.
  8. OSHA RESPONSE: This response assumes the only HCS 2012-covered hazard presented by the chemical is that related to combustible dust. On your first question, the workplace labeling requirement would begin only once the chemical is brought into the work area where it will be processed in a way to create the combustible dust hazard. On your second question, 1910.1200(f)(7) states that for stationary process containers, the employer may use signs or placards "as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(6) of this section to be on the label." Thus, for stationary process containers, so long as the signs or placards used in your scenario are easily visible to the employees in the work area, convey the information required by (f)(6), and identify the containers to which they are applicable, the employer's workplace labeling obligation for the chemical would be satisfied. Other containers must bear the information specified in (f)(6). At a minimum, (f)(6) requires the product identifier and words, pictures and/or symbols that provide general information of the hazard, and in conjunction with other information immediately available to the employees, provides employees with the specific information about the combustible dust hazard.
Finally, the workplace labeling requirements in (f)(6) apply only to chemicals that are in containers. Thus, individual boards or pipes that might create a combustible dust hazard when cut do not need to be labeled under (f)(6). It is permissible (and OSHA encourages) the use of signs or placards to advise workers of the hazard in such circumstances, but signs and placards are not required.

Of course, the employer has other responsibilities under HCS 2012 for these products as well, including training, maintaining SDSs, and providing SDSs to employees in an easily accessible manner.

Friday, October 4, 2013

Training Materials for GHS Aligned Hazard Communication Standards (HCS)

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. 

Benefits: The new standard covers over 43 million workers who produce or handle hazardous chemicals in more than five million workplaces across the country. The modification is expected to prevent over 500 workplace injuries and illnesses and 43 fatalities annually. Once fully implemented it will also:
  • Improve the quality and consistency of hazard information in the workplace, making it safer for workers to do their jobs and easier for employers to stay competitive;
  • Enhance worker comprehension of hazards, especially for low and limited-literacy workers, reduce confusion in the workplace, facilitate safety training, and result in safer handling and use of chemicals;
  • Provide workers quicker and more efficient access to information on the safety data sheets;
  • Result in cost savings to American businesses of more than $475 million in productivity improvements, fewer safety data sheet and label updates and simpler new hazard communication training: and
  • Reduce trade barriers by harmonizing with systems around the world.
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 and when:
  • 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.
Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and SDS format. Employers
June 1, 2015*

December 1, 2015
Comply with all modified provisions of this final rule, except:

Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.
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. Employers
Transition Period Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors and employers
* This date coincides with the European Union implementation date for classification of mixtures.

National Safety Compliance Inc has produced an excellent GHS/Hazard Communication In-Depth Training Kit for just $345.  For more information regarding this package, feel free to contact them at or 1-877-922-7233

Tuesday, September 24, 2013

OSHA & Canadian Health Dept Sign Memorandum of understanding hazard communication standards

June 19, 2013
Contact: Office of Communications
Phone: 202-693-1999

OSHA and Canadian health department sign Memorandum of Understanding
to align hazardous communication standards

WASHINGTON – The Occupational Safety and Health Administration today signed a Memorandum of Understanding with the Healthy Environments and Consumer Safety Branch of the Department of Health of Canada. The MOU allows OSHA and HECS to collaborate on implementing the Globally Harmonized System of Classification and Labelling in their respective jurisdictions, as well as any future developments of the GHS.

"Today we live and work in a global environment with varying and sometimes conflicting national and international requirements," said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. "Through GHS and now this MOU, OSHA and Health Canada have forged a relationship to jointly provide concise information to protect those exposed to hazardous chemicals."
During a ceremony today at U.S. Department of Labor headquarters in Washington, D.C., Dr. David Michaels, assistant secretary of labor for occupational safety and health signed a partnership agreement with Suzy McDonald, director general, Workplace Hazardous Materials Directorate, HECS. Under the agreement, OSHA and HECS will establish a working group to reduce systematic barriers between the systems responsible for occupational safety and health of workplace chemicals and collaborate to reach common positions for the United Nations Sub-Committee of Experts on the GHS about proposed updates to the system, among other goals.

OSHA is participating in the US-Canada High Level Regulatory Coordination Council to improve regulatory cooperation and adopt compatible approaches to promote economic growth, job creation and benefits to consumers and businesses through increased regulatory transparency and coordination.
OSHA aligned its Hazard Communication Standard with the GHS in March 2012 to provide a common, understandable approach to classifying chemicals and communicating hazard information on labels and safety data sheets. In the U.S., all employers with hazardous chemicals in the workplace must conduct new training for workers on the new label elements and safety data sheets format to facilitate recognition and understanding. This training must be done by Dec. 1, 2013.

Further information for workers, employers and downstream users of hazardous chemicals can be reviewed at OSHA's Hazard Communication Web page at, which includes links to OSHA's revised Hazard Communication Standard and guidance materials such as frequently asked questions and OSHA fact sheets and Quick Cards.

Tuesday, September 10, 2013

Estimated benefits of Hazard Communication revision

Q: What are the estimated benefits attributable to the revised Hazard Communication Standard?

A: OSHA expects that the modifications to the Hazard Communication Standard (HCS) will result in increased safety and health for the affected employees and reduce the numbers of accidents, fatalities, injuries, and illnesses associated with exposures to hazardous chemicals. The GHS revisions to the HCS standard for labeling and safety data sheets would enable employees exposed to workplace chemicals to more quickly obtain and to more easily understand information about the hazards associated with those chemicals. In addition, the revisions to HCS are expected to improve the use of appropriate exposure controls and work practices that can reduce the safety and health risks associated with exposure to hazardous chemicals.

OSHA estimates that the revised HCS will result in the prevention of 43 fatalities and 585 injuries and illnesses (318 non-lost-workday injuries and illnesses, 203 lost-workday injuries and illnesses, and 64 chronic illnesses) annually. The monetized value of this reduction in occupational risks is an estimated $250 million a year on an annualized basis.

OSHA estimates that the revised HCS will result in savings of $475.2 million from productivity improvements for health and safety managers and logistics personnel, $32.2 million during periodic updating of SDSs and labels, and $285.3 million from simplified hazard communication training.

OSHA anticipates that, in addition to safety and health benefits, the revised HCS will result in four types of productivity benefits: (1) for chemical manufacturers, because they will need to produce fewer SDSs in future years; (2) for employers, in providing training to new employees as required by the existing OSHA HCS through the improved consistency of the labels and SDSs. (3) for firms engaging in, or considering engaging in, international trade.

Wednesday, September 4, 2013

Training Requirements for the Revised Hazard Communication Standard cont'd

Training on the format of the SDS must include information on:

• Standardized 16-section format, including the type of information found in the various sections

✓ For example, the employee should be instructed that with the new format, Section 8 (Exposure Controls/Personal Protection) will always contain information about exposure limits, engineering controls and ways to protect yourself, including personal protective equipment.

• How the information on the label is related to the SDS

✓ For example, explain that the precautionary statements would be the same on the label and on the SDS.

As referenced in Dr. Michaels’ OSHA Training Standards Policy Statement (April 28, 2010) – with all training, OSHA requires employers to present information in a manner and language that their employees can understand. If employers customarily need to communicate work instructions or other workplace information to employees in a language other than English, they will also need to provide safety and health training to employees in the same manner. Similarly, if the employee’s vocabulary is limited, the training must account for that limitation. By the same token, if employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation.

OSHA’s Hazard Communication website has the following QuickCards and OSHA Briefs to assist employers with the required training.

• Label QuickCard (English/Spanish)
• Pictogram QuickCard (English/Spanish)
• Safety Data Sheet QuickCard (English) (Spanish)
• Safety Data Sheet OSHA Brief
• Label/Pictogram OSHA Brief (to come)

Tuesday, August 27, 2013

Training Requirments for the Revised Hazard Communication Standard cont'd

✓ Pictogram: OSHA’s required pictograms must be in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame sufficiently wide enough to be clearly visible. A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label. OSHA has designated eight pictograms under this standard for application to a hazard category.

✓ Hazard statement(s): describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.” All of the applicable hazard statements must appear on the label. Hazard statements may be combined where appropriate to reduce redundancies and improve readability. The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it.

✓ Precautionary statement(s): means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.

✓ Name, address and phone number of the chemical manufacturer, distributor, or importer

• How an employee might use the labels in the workplace. For example,

✓ Explain how information on the label can be used to ensure proper storage of hazardous chemicals.

✓ Explain how the information on the label might be used to quickly locate information on first aid when needed by employees or emergency personnel.

• General understanding of how the elements work together on a label. For example,

✓ Explain that where a chemical has multiple hazards, different pictograms are used to identify the various hazards. The employee should expect to see the appropriate pictogram for the corresponding hazard class.

✓ Explain that when there are similar precautionary statements, the one providing the most protective information will be included on the label.

Tuesday, August 20, 2013

Training Requirments for the Revised Hazard Communication Standard

December 1st, 2013 Training Requirements for the Revised Hazard Communication Standard

OSHA revised its Hazard Communication Standard (HCS) to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and published it in the Federal Register in March 2012 (77 FR 17574). Two significant changes contained in the revised standard require the use of new labeling elements and a standardized format for Safety Data Sheets (SDSs), formerly known as, Material Safety Data Sheets (MSDSs). The new label elements and SDS requirements will improve worker understanding of the hazards associated with the chemicals in their workplace. To help companies comply with the revised standard, OSHA is phasing in the specific requirements over several years (December 1, 2013 to June 1, 2016).

The first compliance date of the revised HCS is December 1, 2013. By that time employers must have trained their workers on the new label elements and the SDS format. This training is needed early in the transition process since workers are already beginning to see the new labels and SDSs on the chemicals in their workplace. To ensure employees have the information they need to better protect themselves from chemical hazards in the workplace during the transition period, it is critical that employees understand the new label and SDS formats.
The list below contains the minimum required topics for the training that must be completed by December 1, 2013.

Training on label elements must include information on:
• Type of information the employee would expect to see on the new labels, including the

✓ Product identifier: how the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS (Identification).

✓ Signal word: used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. There are only two signal words, “Danger” and “Warning.” Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. There will only be one signal word on the label no matter how many hazards a chemical may have. If one of the hazards warrants a “Danger” signal word and another warrants the signal word “Warning,” then only “Danger” should appear on the label.

Tuesday, August 13, 2013

NFPA 704 “diamond” and OSHA GHS labels

When OSHA announced last year that it was updating its Hazard Communication Standard to include the adoption of the Globally Harmonized System of Classification and Labeling of Chemicals, many companies and emergency responders asked “How will this impact NFPA 704”?  NFPA 704, Identification of the Hazards of Materials for Emergency Response, uses a combination of color coding and numbers to describe a hazard’s severity, and provides a simple, readily recognized, and easily understood label to assist those who are responding to an emergency such as a fire or spill. OSHA’s revised Standard, known as Hazard Communication 2012 or HC2012, is a workplace chemical information system established primarily to provide information and safe work practices for those working with chemicals on a routine basis through the use of labels, Safety Data Sheets (SDSs) and training.  

The concern is that the HC2012 standard incorporates a numerical rating system that appears to be similar to NFPA 704 rating system, however the severity rating on the two standards are inverted.   NFPA 704 uses a numerical of 0-4 with 4 indicating themost severe hazard.   Hazard Communication 2012 uses a numerical rating system for classification of chemicals between 1-4 with a 4 rating indicating the least severehazard.  The inverse numerical rating between the two systems is primarily what creates the concern.

To address this concern, NFPA has been working with OSHA over the past year to promote awareness of the differences between the two systems. It should be noted that OSHA does not necessarily see a conflict between HCS and NFPA 704.  OSHA has indicated that the GHS numbers are not relative ratings of hazards but are used for the purpose of classifying hazards into categories for proper labeling and training information. The numbers for GHS will be placed on the SDS but are not required to be on labels. 

 Recently OSHA and NFPA worked together to develop a “Quick Card” showing the differences between the two systems. The Quick card can be found on the NFPA Document information page for NFPA 704  at the bottom of the page under “Additional Information”. Or you may go directly to the Quick Card.   The card can be downloaded and laminated as a two sided document that can be used for easy field reference.    

The NFPA Technical Committee on Classification will continue to assess the impact of GHS incorporation into OSHA’s HC2012 standard.  In the meantime, there is no immediate plan to change the existing NFPA 704 system.   The Committee recognizes that the NFPA 704 consensus standard has been protecting emergency responders, employees, and the public for over 50 years and any changes would need to be carefully considered.   For updates on NFPA 704 it is recommended that you sign up for email alerts on the top of the document information page for NFPA 704.

Friday, August 2, 2013

White House releases executive order on improving chemical facility safety and security!

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The President signed an Executive Order to improve the safety and security of chemical facilities and reduce the risks of hazardous chemicals to workers and communities. Incidents such as the devastating explosion at a fertilizer plant in West, Texas in April are tragic reminders that the handling and storage of chemicals present serious risks that must be addressed. The Executive Order directs Federal agencies to work with stakeholders to improve chemical safety and security through agency programs, private sector initiatives, Federal guidance, standards, and regulations. Read the executive order.

Tuesday, July 30, 2013

TLVs, OSHA addressed hazards under HCS not changed by the GHS?

Q. Will TLVs be required on the Safety Data Sheet (SDS)?

A. OSHA is retaining the requirement to include the American Conference of Government Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) on the safety data sheet (SDS) in the revised Standard. OSHA finds that requiring TLVs on the SDS will provide employers and employees with useful information to help them assess the hazards presented by their workplaces. In addition to TLVs, OSHA permissible exposure limits (PELs), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet are also required.

Q. May the International Agency for Research on Cancer (IARC) and the National Toxicology Program (NTP) lists be used to make carcinogen classifications?

A. In the revised HazardCommunication Standard (HCS), OSHA has provided classifiers with the option of relying on the classification listings of IARC and NTP to make classification decisions regarding carcinogenicity, rather than applying the criteria themselves. OSHA believes that this will make classification easier for classifiers, as well as lead to greater consistency. In addition, OSHA has provided in non-mandatory Appendix F of the revised rule, guidance on hazard classification for carcinogenicity. Part A of Appendix F includes background guidance provided by GHS based on the Preamble of the IARC "Monographs on the Evaluation of Carcinogenic Risks to Humans" (2006). Part B provides IARC classification information. Part C provides background guidance from the National NTP "Report on Carcinogens" (RoC), and Part D is a table that compares GHS carcinogen hazard categories to carcinogen classifications under IARC and NTP, allowing classifiers to be able to use information from IARC and NTP RoC carcinogen classifications to complete their classifications under the GHS, and thus the HCS.

Q. Will the International Agency for Research on Cancer (IARC) and the National Toxicology Program (NTP) classifications be required on the Safety Data Sheet (SDS)?

A. OSHA has retained the requirement to include IARC and NTP classifications on safety data sheets (SDSs). Therefore, if a chemical is listed as a carcinogen by either IARC or NTP, it must be noted on the SDS. Additionally, if OSHA finds a chemical to be a carcinogen, it must be noted on the SDS as well. 

Q. How has OSHA addressed hazards covered under the current Hazard Communication Standard that have not been addressed by the GHS?

A. In the Notice of Proposed Rulemaking (NPRM), OSHA proposed to include hazards currently covered under the Hazard Communication Standard (HCS) that have yet to be addressed by the GHS (OSHA provided several examples: simple asphyxiants, and combustible dust) in a separate category called "Unclassified Hazards". In response to comments from the regulated community, OSHA has renamed the category to "Hazards Not Otherwise Classified (HNOC)" to minimize confusion. In the final HCS, HNOC hazards will not be required to be disclosed on the label but will be required to be disclosed in section 2 of the Safety Data Sheet (SDS). This reflects how GHS recommends these hazards should be disclosed. Chemical manufacturers and importers are expected to assess these hazards when they are conducting their hazard evaluation of physical and health hazards. A new or separate evaluation is not required. Also in the final standard, in response to comments, OSHA has removed pyrophoric gases, simple asphyxiants, and combustible dust from the HNOC hazard category and has addressed these chemicals individually (see question below for more information on each hazard).

Friday, July 19, 2013

New Hazard Communication Standard (HCS) questions.

Q. Can I use a black border on pictograms for domestic shipment?

A. Under the revised Hazard Communication Standard (HCS), pictograms must have red borders. OSHA believes that the use of the red frame will increase recognition and comprehensibility. Therefore, the red frame is required regardless of whether the shipment is domestic or international.

Q. Will OSHA allow blank red borders?

A. The revised Hazard Communication Standard (HCS) requires that all red borders printed on the label have a symbol printed inside it. If OSHA were to allow blank red borders, workers may be confused about what they mean and concerned that some information is missing. OSHA has determined that prohibiting the use of blank red borders on labels is necessary to provide the maximum recognition and impact of warning labels and to ensure that users do not get desensitized to the warnings placed on labels.

Q. When must label information be updated?

A. In the revised Hazard Communication Standard (HCS), OSHA is lifting the stay on enforcement regarding the provision to update labels when new information on hazards becomes available. Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information. If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.

Q. How will workplace labeling provisions be changing under the revised Hazard Communication Standard?

A. The current standard provides employers with flexibility regarding the type of system to be used in their workplaces and OSHA has retained that flexibility in the revised Hazard Communication Standard (HCS). Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard. Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms. 

Q. How is the Safety Data Sheet (SDS) changing under the revised Hazard Communication Standard?

A. The information required on the safety data sheet (SDS) will remain essentially the same as that in the current standard. The current Hazard Communication Standard (HCS) indicates what information has to be included on an SDS but does not specify a format for presentation or order of information. The revised HCS requires that the information on the SDS is presented using consistent headings in a specified sequence.

Paragraph (g) of the final rule indicates the headings of information to be included on the SDS and the order in which they are to be provided. In addition, Appendix D indicates what information is to be included under each heading. The SDS format is the same as the ANSI standard format which is widely used in the U.S. and is already familiar to many employees.