As you probably know, OSHA is revising its old Hazard Communication 1994 Standard and has created a new Hazard Communication 2012 Standard. The new HazCom 2012 Standard is “aligned” with the Globally Harmonized System, also known as GHS.
You may also know that employers have an obligation to train their employees about certain aspects of the new GHS-aligned HazCom 2012 Standard before December 1, 2013 (this year). This deadline is mentioned on OSHA’s website on a page titled Effective Dates. And it has also been the subject of one of our earlier blog posts explaining What to Know and Do for HazCom 2012/GHS During 2013.
But, you’d be forgiven if you didn’t know that OSHA recently published a Fact Sheet titled December 1st, 2013 Training Requirements for the Revised Hazard Communication Standard. That’s because it’s brand new. We just recently learned of it ourselves.
For the most part, the new Fact Sheet restates stuff we’ve already known, but there are some new wrinkles, too. Let’s take a look in more detail:
The new Fact Sheet lists some things we already knew about the training requirements. These include:
These aren’t absolutely new items or changes, but places where OSHA has provided more guidance about what the training should cover. They include:
In addition to this Training Requirements Fact Sheet, OSHA has also published two other new documents:
Reading the information in these two documents will also help you create your new HazCom 2012 training programs. For example, the brief about labels and pictograms includes information about how labelers can combine or shorten hazard statements and precautionary information, explains that pictograms on workplace labels can have a black or red border (red is required for shipping labels), and explains a somewhat significant change that OSHA plans for the future:
“If a label has a DOT transport pictogram, Appendix C.2.3.3 states that the corresponding HCS pictogram shall not appear. However, DOT does not view the HCS pictogram as a conflict and for some international trade both pictograms may need to be present on the label. Therefore, OSHA intends to revise C.2.3.3. In the meantime, the agency will allow both DOT and HCS pictograms for the same hazard on a label. While the DOT diamond label is required for all hazardous chemicals on the outside shipping containers, chemicals in smaller containers inside the larger shipped container do not require the DOT diamond but do require the OSHA pictograms.”