Thursday, May 30, 2013

Labeling & SDS Changes in new Hazcom Regulations

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 (HazCom 1994). HazCom 1994 indicates what information has to be included on an SDS, but does not specify a format for presentation or order of information. The revised Hazard Communication Standard (HazCom 2012) requires that the information on the SDS be presented using specific headings in a specified sequence.
Paragraph (g) of the final rule provides the headings of information to be included on the SDS and the order in which they are to be provided. In addition, Appendix D provides the information 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.
The format of the 16-section SDS should include the following sections:
  • Section 1. Identification
  • Section 2. Hazard(s) identification
  • Section 3. Composition/information on ingredients
  • Section 4. First-Aid measures
  • Section 5. Fire-fighting measures
  • Section 6. Accidental release measures
  • Section 7. Handling and storage
  • Section 8. Exposure controls/personal protection
  • Section 9. Physical and chemical properties
  • Section 10. Stability and reactivity
  • Section 11. Toxicological information
  • Section 12. Ecological information
  • Section 13. Disposal considerations
  • Section 14. Transport information
  • Section 15. Regulatory information
  • Section 16. Other information, including date of preparation or last revision
The SDS must also contain Sections 12-15, to be consistent with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Although the headings for Sections 12-15 are mandatory, OSHA will not enforce the content of these four sections because these sections are within other agencies' jurisdictions.

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.

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