In March 2012, OSHA revised its Hazard Communications Standard (HCS) to align it with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  The GHS is an international approach to hazard communication.  Developed over many years and by many countries, it sets uniform requirements for hazard communication to improve the quality and consistency of information.  Among other changes, the revised HCS requires a new labeling system and a standardized format for Safety Data Sheets (SDSs), formally known as Material Safety Data Sheets (MSDSs).  The new standard will be phased in through 2016.  The first deadline of December 1, 2013 requires all employers to train employees on the new label and SDS formats.

Many employers have already started their transition to the revised HCS.  Those who have not should act soon to meet the December 1, 2013 training deadline.  Employers should expect OSHA inspections conducted after December 1st to not only include verification of the required label/SDS training, but inspection of the employer’s overall compliance with the HCS.

Meeting the December 1st training deadline should not be difficult for most employers.  Unlike comprehensive HCS training that must be given to all new employees, the label/SDS training only requires an explanation of the new label elements and the new SDS format.  The revised standard is silent on the specific content of the training.  However, in a “Fact Sheet” on OSHA’s website, OSHA lists what it considers to be the “minimum required topics.”  The “Fact Sheet” is not a mandatory legal requirement, but to avoid disputes about the adequacy of their training, employers should consider OSHA’s guidance.

As to the new label elements, OSHA expects the training to cover:

  • The “Product Identifier” or how the hazardous chemical is defined by chemical name, code or batch number.
  • The “Signal Word” used to indicate the relative severity of the chemical hazard.  There are only two signal words, “Danger” and “Warning.”  “Danger” is used for more severe hazards.  “Warning” is used for less severe hazards.
  • The “Pictograms” designated by OSHA to identify the hazard classification, such as “Corrosion” or “Flame.”  There are nine designated pictograms.
  • The “Hazard Statement,” which describes the nature of the chemical hazard, such as “causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.”
  • The “Precautionary Statement,” which describes the recommended measures that should be taken to minimize or prevent adverse effects, such as “keep away from heat.”
  • The name, address and phone number of the chemical manufacturer and distributor.
  • How employees can use the labels in the workplace, for example, to locate needed first aid information, and how the label elements work together by, for example, describing multiple pictograms used to identify multiple hazards.

As to the new SDS format, OSHA expects the training to cover:

  • A description of the standardized 16-section format including the types of information found in each.  For example, employees should be told that Section 8 of the new SDS (exposure controls/personal protection) will contain information about exposure limits, engineering controls and personal protective equipment.
  • How the information on the label is related to the SDS.  For example, employees should be told that the “Precautionary Statements” are the same.

Employers are reminded that the new label/SDS training must be given to existing employees by December 1, 2013, and all new employees after that date.  This can be done by incorporating the label/SDS training topics into the employer’s existing HCS training program.