The following information is contributed by Rick Hartwig and the Environmental, Health, and Safety Affairs Department of Printing Industries of America.
Get ready for changes to your Hazard Communication program! After years of effort, theOccupational Safety and Health Administration (OSHA) revised its Hazard Communication Standard (HCS) to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The revision was made to provide for consistency and to allow employees to better understand hazards, which will result in improved compliance, easier program management, and fewer injuries and illnesses.
The changes outlined under the new standard will be phased in over time and will be fully in effect by June 1, 2016. This rule includes three major changes to the current standards:
- Hazard classification. The definitions of “hazard” have been changed to provide specific criteria for classifications of health and physical hazards, as well as the classification of mixtures. The chemical manufacturer and importer are still responsible for hazard classification.
- Labels for chemical containers. Chemical manufacturers and importers will be required to provide a label that includes a signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
- Safety data sheets. These documents will eventually replace the Material Safety Data Sheet (MSDS) and will now have a uniform and specified 16-section format. The compliance requirements for the Safety Data Sheet (SDS) will essentially be the same as was required in the current standard.
As a result of the changes to labeling and SDS’s, OSHA will require modified employee training to be provided. The revised rule requires that all applicable workers be trained on the new label elements and SDS format by December 1, 2013 in order to be prepared once the new information is released into the market. Also, in the event any new physical or health hazards are identified, additional employee training on the new information must be completed by June 1, 2016. This modified training is in addition to the current standard’s training requirements.
The printing industry will primarily be affected by the labeling and Safety Data Sheet changes to the Hazard Communication Standard, as well as the training requirements that accompany these changes. OSHA will require employers who use an in-plant labeling system to update their labeling program, so companies should begin evaluating the labeling system used for in-plant containers during the transition period.
Although the changes do not directly affect the written program requirements of Hazard Communication Standard, OSHA will require employers to update, as necessary, any portion of their programs that would reflect changes such as terminology, definitions, training, or any change in policies as a result of the new revision.
To prepare companies for the implementation of the new Hazard Communication standard OSHA has provided an online resource(http://www.osha.gov/dsg/hazcom/index.html) that contains the text of the final rule, fact sheets, frequently asked questions, and additional information about the new rule. Further information and guidance will be made available after a review is performed by the Environmental, Health, and Safety Affairs team at Printing Industries of America.
For questions or more information regarding Environmental, Health, and Safety, contact Rick Hartwig, Manager, Environmental Health and Safety Affairs, Printing Industries of America, at rhartwig@printing.org.
Also, join Printing Industries of America Networking Group on LinkedIn to start your own discussion with others in your industry.