Hazard Communication (HAZCOM)as we know it today came about in 1983 as a direct result of 29CFR 1910.1200. According to the latest OSHA Fall Agenda (1), HAZCOM as we know it will change as of August, 2011 with the promulgation of the much talked about changes to the Hazard Communication Standard (HCS) specifically related to The Globally Harmonized System of Classification and Labelling of Chemicals (GHS.) How will the transition to the new HCS impact your average safety manager in an industrial application? To answer that question, I want to outline the current HCS requirements and then look more in depth at the upcoming changes related to GHS and how best to plan for the transition.

At a 10,000 foot view, current HAZCOM consists of the Employee’s Right to Know about the hazardous chemicals in the workplace. Broken down into a more basic view—HAZCOM consists of the communication of the hazards in the workplace via a written program, a training element, and readily accessible material safety data sheets (MSDS) for employees. Much has been written about the current state of HAZCOM, so I want to focus on the significant proposed changes to the HCS and some tips on how to transition your organization at the proper time.

OSHA has taken all of the formal steps prior to publishing the final rule. The Notice of Proposed Rule Making occurred in September of 2009. Comments were taken through December 31, 2009, public hearings were held in early 2010 and the public record was closed in June, 2010. OSHA published in their fall agenda an August, 2011 date for publication of the final rule. This means that the new HCS is slated to be law before the end of this year!

So, what are the significant changes and impacts to the current HCS as a result of GHS? OSHA has provided an initial comparison that can be found on their website at http://www.osha.gov/dsg/hazcom/ghoshacomparison.html . To break this down a bit; there are four main elements—the MSDS, Labeling, Communication, and Training.

The changes to the MSDS are quite possibly the most significant and far reaching. First and foremost the proposed rule suggests a new name – simply safety data sheet (SDS) and adopts a required format (16 section in specified order). An even more significant change is that the new guidelines require specific content in a specific format. This is a positive in that those authoring SDS must classify their materials where possible using GHS rules which will standardize the hazard classifications of materials—thus standardizing the SDS. Section 2 of the SDS will be the Hazards Identification and will have standardized phrases, signal words, and pictograms. Section 3 becomes the component section listing the substances that make up the material as a whole. The real benefit here long term is that the training and education of employees on the hazards of materials will be easier once everyone transitions.

Changes to Labeling requirements, specifically what is required on the label, are also significant. In the past many companies have used NFPA or HMIS type labels for their workplace labeling needs. When a material is added to a secondary container, a label must be created that lists the hazards and identifies the material. The new labeling requirements go a bit further requiring the name of the material, GHS signal words, GHS Hazard and Precautionary Statements, and GHS pictograms. In addition, three label elements must be located together—the Signal Word, Hazard Statements and Pictograms. A major difference in many current labeling formats is that a “1” rating means the least hazardous with a “4” rating being the most hazardous. GHS is the opposite in that a “1” classification is the most hazardous with a “5” being the least hazardous.

A significant impact will be the communication of these changes downstream. Manufacturers are required to submit new, revised MSDS for significant changes—of which the new HCS will be! This means that EVERY MSDS (now SDS) you manage in your facility will be updated if the manufacturer (and YOU) want to remain in compliance. Prepare for a SIGNIFICANT influx of new, updated MSDS. If you don’t have a vendor that manages these documents and the data found on them, now is the time to find one that provides the best service and is prepared for GHS!

Finally, you will need to update your current HAZCOM program to reflect the changes in HCS. Employees must be trained on the new content and format of both SDSs and Labels. An understanding of the chemical hazards in the workplace will be necessary as it relates to the new classifications, pictograms, signal words, and labels. In the long term, this is a benefit as employees will be able to understand the standardized hazard information more readily, hazards will be more clearly defined, and information will be more accurately disseminated.

Currently, the timeline OSHA has proposed is to publish the final rule in August of 2011. The NPRM proposed a two year training window and a three year full transition window. At the end of three years from promulgation of the final rule, all SDS have to meet the content and format requirements and all labeling, communication, and training will have to be compliant with the new standard. Both the current and proposed HCS will be acceptable until the end of the 3 year transition period.

This means that transition planning now is an important “to do” for 2011! If it isn’t on your current list, I recommend you consider adding it. Companies that do business in Europe or the Far East already must meet GHS requirements and we are seeing GHS compliant SDS in the workplace here in the US.

Here are four transition tips that may help you in your HCS transition planning:
1. Get informed and watch the timetables to know exactly when OSHA publishes the final rule!
2. Don’t go it alone—prepare management for the upcoming change and the needs you will have to insure a successful, compliant transition.
3. Leverage your chemical data management system—or invest in one that will aid in the successful transition of your organizations HAZCOM program.
4. Finally—pick a timeframe for your organization’s transition to occur prior to the deadline and put a plan in place to meet that date!

The world is changing—being prepared for the transition is the first step to being successful and promoting a safe, risk-free work environment!

R. Scott Williams
Director of Sales, SiteHawk
R. Scott Williams is the Director of Sales for SiteHawk and has over 20 years of experience in the EH&S consulting and management field. With a background in environmental and safety consulting, Scott’s role is to advise companies in the evaluation and selection of electronic chemical data management systems.

EXTERNAL LINK
OSHA: A Guide to The Globally Harmonized System of Classification and Labelling of Chemicals (GHS)