As you know the Occupational Safety and Health Administration (OSHA) has revised Hazard Communication Standard (HCS), which means a new to-do list for many printers. Last time we told you about the EHS resources available even if you missed the initial training deadline of December 2013.
Here is a “Who, What, Why, When, and Where” overview to give you a clearer explanation of what you need to do and when to do it to remain in compliance.
WHO Do These New Standards Affect?
All printing operations are subject to the Hazard Communication Standard because of the use of chemicals such as inks, toners, cleaning solutions, etc. As a printing operation, you must provide information to your employees about the hazards associated with your chemicals, including how to work with them in a safe manner through labels and Safety Data Sheets (SDSs), which are replacing the Material Safety Data Sheet (MSDS) and provide more detailed information in a uniform format.
WHAT Actions Must My Company Take?
The Hazard Communication Standard requires all employers with hazardous chemicals in their workplaces to:
- Prepare and implement a written hazard communication program.
- Develop a written inventory of products that contain hazardous chemicals.
- Obtain, maintain, and make available to employees SDSs for all products on the written inventory.
- Ensure all containers, including in-plant or secondary ones, are properly labeled.
- Conduct employee training.
Due to the revisions made by OSHA to incorporate the GHS (the Globally Harmonized System of Classification and Labeling Chemicals), there are several changes printing operations need to make within the next two years to meet the new requirements. The main areas covered follow.
Initial employee training to be completed by December 1, 2013. If you have not started training your employees yet or need help, see the training materials here (member login required).
The deadline for revising chemical container labels is December 1, 2015. The completely revised product label requirements mandate that specific information must be included on each label. These new requirements state that labels will now require all of the following:
- Product identifier
- Signal word
- Hazard statement(s)
- Precautionary statement(s)
- Supplier information
For more information on the pictograms, see theSafety Poster – Pictograms Quick Reference.
In-plant container labels also require special attention. The revised standards acknowledge the same secondary container rule: If an employee transfers a material from a labeled container to a secondary container, which is intended only for immediate use by that employee, and that employee understands the hazards associated with the material, then that container does not have to be labeled unless it is either stored for future use or passed to another employee.
One major change to the in-plant labeling system is to the Hazard Materials Identification System (HMIS). The HMIS numeric coding states that hazard categories (health or physical) are based on the degree of severity with a numeric rating from zero to four, with four representing the greatest severity. However, with the new rule aligned with GHS, the opposite numbering order is true with respect to hazard determination. Under the new rule, a Category 1 of any hazard is the highest level of severity. Because of this difference in rating and the potential for confusion in recognizing hazard severity, the HMIS system is not recommended for in-plant alternative labeling until such time as the HMIS system is revised to align with the GHS.
Safety Data Sheets, the newly aligned MSDS, provides 16 sections addressing issues involving product and hazard identification, ingredients, and toxicological information, first aid and fire-fighting measures, handling and storage, and more. Check out theSafety Poster—Get to Know the Safety Data Sheet for a full list.
Additionally, under the HCS there is a new hazard classification—“Hazards Not Otherwise Classified.” This new class requires any chemicals not listed in the other sections should be disclosed in Section 2 of the SDS, Hazards Identification. They are not, however, required to be disclosed on the hazard warning label. To avoid confusion with the “Hazard Not Otherwise Classified” category, OSHA revised the definition of “Hazardous Chemical” to include pyrophoric gases, simple asphyxiants, and combustible dust.
Lastly, Employee Information Training must include the following topics:
- Methods and observations workers can use to detect the presence or release of a hazardous chemical in the work area.
- The physical hazards of chemicals in their work area.
- The health hazards of chemicals in their work area.
- Measures workers can take to guard against physical and health hazards (e.g., appropriate work practices, emergency procedures, and personal protective equipment use).
- Details of your hazard communication program, including location and availability of the written hazard communication program and the required list of hazardous chemicals and MSDSs/SDSs, an explanation of the workplace labeling system, and how to read and use SDSs to obtain hazard information.
WHY Did OSHA Revise These Regulations?
The most recent changes to HCS were done for several reasons, with the primary ones focusing on standardizations and harmonization with similar systems around the world. The expected benefits of these changes are fewer updates to safety data sheets and labels, as well as simpler hazard communication training. The revisions should also reduce trade barriers by allowing for a more uniform approach that is recognized around the world.
WHEN Must Our Operation Meet These New Requirements?
The phase-in period OSHA has implemented will span the next couple of years. Key due dates for print operation employers are:
- December 1, 2013—Complete initial training of employees in understanding the new container labels and SDSs
- December 1, 2015—Full compliance with label requirements
- June 1, 2016—Updated internal workplace labeling systems and completed employee labeling training
WHERE Can We Find Help Implementing These Changes?
We have some great news for any printing operation looking to integrate the new GHS program elements. There are several tools you can use to examine your current plan, develop a new plan, and incorporate these elements immediately:
The Hazard Communication Guidance for Printing Operations is a free online resource to help our members fulfill training requirements (available for purchase for non-members in the bookstore). Here you will find:
- Updated SDS and labeling information
- Instructions, sample programs, and forms for developing your HCS program
- Training tools (videos, PowerPoint, etc.)
In addition, the EHS Department offers consulting services to assist its members in developing and implementing a Hazard Communication program. The range of services includes reviewing existing programs and providing feedback through developing a complete turnkey training program. Contact the EHS Department by clicking here for more information.
Contact the EHS experts at Printing Industries of America! Visit www.printing.org/ehs or call 800-910-4283 ext. 794.