OSHA's New Hazard Communication Standard - DoctorsManagement OSHA's New Hazard Communication Standard - DoctorsManagement

OSHA’s New Hazard Communication Standard

The Reason Behind the Change
OSHA revised the Hazard Communication Standard (HCS) to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update to the Hazard Communication Standard provides a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets.

Major Changes
Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
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 (see sections below).
Information and training: Employers are required to train workers by December 1, 2013, on the new label elements and safety data sheet format to facilitate recognition and understanding.

Compliance Dates
December 1, 2013 – Employers must have trained employees on pictograms and new SDSs.
June 1, 2016 – Workplace labels must be compliant. Employers must have written HazCom plan and have trained workers.

Program Elements
Labeling
Employee training and information
Chemical list
SDSs
Methods for informing employees on how to handle non-routine tasks
Methods for informing employees of other employers on the written program

Chemical Labeling
Manufacturer labels: Must have all required information
In-house labels: All secondary containers, even nonhazardous, New standard allows new label format with pictograms OR continuance of old labeling.
All labels must be: legible, in English (additional languages if needed), prominently displayed.

Pictograms/Signal Words
Must have symbol inside red diamond
Must be covered in employee training by December 1, 2013
Must be on manufacturer labels by December 1, 2015
Must be on in-house labels for secondary containers by June 1, 2016
OSHA HazCom Pictograms

((( NEED PICTOGRAM IMAGE HERE)

Signal Words
“Danger” is for the more severe hazards.
“Warning” is used for less severe hazards.

Safety Data Sheets 16-Section Format
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
* Regulated by agencies other than OSHA.

Remember, the deadline to complete employee training for OSHA’s new hazardous communications policy is December 1, 2013. Failure to comply could result in OSHA fines/penalties for your practice.

As always, contact us via email or call 800-635-4040 with any questions or concerns.

If you have questions about this topic or any other issues around the business of medicine, contact us via email or call us at 800-635-4040.