OSHA Publishes New HazCom 2012/GHS Alignment Training Requirements Fact Sheet

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 Stuff We Already Knew

The new Fact Sheet lists some things we already knew about the training requirements. These include:

• Employers must train employees “on the new label elements and the SDS format” by December 1, 2013
• The training that employers give to employees about the new label elements must include the type of information the employee should expect to see on the new labels, including the product identifier, signal word, pictogram, hazard statement, precautionary statement(s), and name, address, and phone number of the chemical manufacturer, distributor, or importer. (If this is all new information to you, see this webpage from OSHA and/or this blog post from Convergence Training.)
• The training that employers give to employees about the new safety data sheet (SDS) must include information on the standardized 16-section format and the type of information employees will find in each of the 16 sections. (Again, if this is all catching you off guard, check this page from OSHA and/or this page from Convergence Training.)
• As with all OSHA-mandated training, employers must provide training to employees in a manner that the employees can understand (see the OSHA Training Standards Policy Statement for more on this). For example:
  • If the employer customarily gives work instructions to the employees in a non-English language, then this training should be provided in the same language
  • If the employee has a limited vocabulary, perhaps because he or she speaks English as a second language, the training must take that into account
  • If the employee cannot read, providing the employee with written material for training is not acceptable

The New Wrinkles

These aren’t absolutely new items or changes, but places where OSHA has provided more guidance about what the training should cover. They include:

• The training about the new labels should include information about how the employee might use the labels in the workplace. Examples include:
  • How information on the label can be used to ensure proper storage of hazardous chemicals
  • How the information on the label might be used to quickly locate information on first aid when needed by employees or emergency personnel
• The training about the new labels should also include an explanation of how the elements work together on the label. Examples include:
  • When a chemical has multiple hazards, different pictograms are used to identify the different hazards
  • When there are similar precautionary statements, the one with the most protective information will be included on the label
• How the information on the label is related to the SDS. For example:
  • The precautionary statement(s) listed on the label are the same as those on the SDS

Other New Publications

In addition to this Training Requirements Fact Sheet, OSHA has also published two other new documents:

• Hazard Communication Standard: Labels and Pictograms (OSHA Brief)
• Hazard Communication Standard: Safety Data Sheets (OSHA Brief)

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.”