By now, you’ve probably heard that the new HazCom 2012 standard has been revised to align with the Globally Harmonized System, or GHS. If we just caught you 100% unaware, you are now excused to go read the information on OSHA’s website about the GHS alignment.
However, we suspect most of you know about this, but that you have been wondering just exactly what it means. Or maybe you’ve wondered about a few of the details. If so, the following is for you.
Before December 1, 2013, you have to train your workers on the new elements of a GHS-compliant shipping label and on the new safety data sheet (SDS) format.
Yes. A few, really.
June 1, 2015 is the deadline for compliance with all modified parts of the HazCom standard.
An exception is made for distributors, who can continue shipping chemicals from manufacturers and importers that do not have GHS-compliant shipping labels until December 1, 2015.
And, employers have until June 1, 2016 to update their hazard communications programs as necessary, update alternative workplace labels as necessary, and to provide additional training to employees for any newly identified physical or health hazards.
OSHA has more details about effective dates for HazCom GHS on their site.
Here's an example:
The labels that chemical manufacturers, distributors, and importers must put on containers of hazardous chemicals don’t have to be exactly alike, but they do have to have the following elements.
The label elements are:
Sample GHS-compliant label from OSHA website.
In addition to the six label elements that must appear on all shipping labels as described above, the following are standardized:
Finally, the pictogram(s), signal word, and hazard statement(s) used on the label are all determined by matching the hazard(s) that the chemical presents to specific classes and categories of hazards defined in the HazCom standard (for more on this, see Appendix A for health hazards and Appendix B for physical hazards). The standard then assigns an appropriate pictogram, signal word, and hazard statement to use for each category/class of hazard (see Appendix C for more on this).
There are nine GHS label pictograms, though OSHA only requires the use of eight.
The mandatory pictograms, and the types of hazards they represent, are:
The ninth pictogram represents environmental hazards. Although OSHA doesn’t require its use, other agencies (such as the EPA) may.
You can download free vector GHS symbols here.
When a chemical is being transported, DOT regulations still apply. As a result, “outside” shipping containers still must be labeled with the DOT label or placard (featuring the DOT pictograms).
No. When a DOT pictogram is put on a container, a GHS pictogram should not be on the same container.
Once a chemical is at a workplace, employers have a few labeling options. First, they can continue to use the GHS shipping label or a label with the same format. Or, they can use alternative workplace labels, including the NFPA and HMIS labels you may already be familiar with.
For more on this, see 1910.1200(f)(6)(ii).
A safety data sheet, or SDS, is very similar to what you know of as a Material Safety Data Sheet, or MSDS. In addition to the slight name change, the SDS now has a standard format with information presented in 16 sections. Those sections are:
See the brief on the OSHA website for details about the SDS.
Read our separate posts about requirements for what OSHA is calling hazards not otherwise classified and for pyrophoric gases, simple asphyxiants, and combustible dusts.