On March 26, 2012, OSHA published the revised Hazard Communication Standard (HCS), “harmonizing” it with portions of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). In order to minimize the disruptions to employers, OSHA phased in the requirements of the revised standard over four years.
The previous, staggered compliance dates for HCS implementation addressed employee training; container labeling and safety data sheets (SDSs); and employer compliance with written plan and labeling requirements.
The final implementation date is June 1, 2016. By that date, all employers must:
- Update alternative workplace labeling as necessary,
- Update their hazard communication (HazCom) program as necessary, and
- Provide additional employee training for newly identified physical or health hazards.
Because of the way OSHA now identifies, or “classifies,” chemical hazards, your chemicals may have “new” hazards. To identify these new chemical hazards, OSHA expects the employer, or whoever is responsible for the workplace HazCom program, to review the container labels and the SDSs for the hazard classifications.
Where new hazards are identified on the label or the SDS, because of the adoption of GHS classifications, those new hazards must be reflected in the HazCom program, as needed. If you identify new chemical hazards, you must make sure that workplace labeling reflects those new hazards and that employees are trained on those hazards.For instance, a chemical might now carry a classification as an eye irritant or as corrosive to metal.
These new hazards would have to be evaluated and be reflected in the written program and employee training, or the chemical may not have been considered hazardous before, but it is considered hazardous under the new classification system.
OSHA believes that most employers will not have to make extensive revisions to their written programs, including the chemical inventory, because of the June 1 date.
But because that date is coming up, employers can use it as an opportunity to examine their HazCom program for compliance. Ensuring that your program addresses OSHA’s requirements, especially the means of communicating information to employees in the workplace, will help you stay in compliance.