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.