Changes In Chemical Management Part 1: OSHA Adopts GHS
This is the first installment of a three part series examining the changing landscape of chemical management.
This week focuses on recent changes to the Hazard Communication Standard (a.k.a. HazCom or HCS) by OSHA and the corresponding deadlines and responsibilities every employer with hazardous chemicals must adhere to. Week two will focus on specific steps employers can take to meet the first compliance deadline, December 1, 2013. Finally, week three will examine chemical management best practices and how recent technical innovations can drive HazCom compliance.
OSHA Aligns HazCom Standard with GHS
In 1983, the manufacturing industry became the first industry covered by OSHA’s Hazard Communication Standard. In 1987, the standard was expanded to include all industries where employees are exposed to hazardous chemicals. Summed up briefly, the standard covers the right of employees to know the chemical hazards to which they are exposed and outlines the responsibilities of chemical manufacturers, distributors and employers to convey that information in a systematic way to downstream users.
In 2012, OSHA revised the standard to align with the United Nation’s Globally Harmonized System of Classification and Labelling of Chemicals, also known as GHS. It was the most significant update to the HazCom Standard since its inception. At the United Nations level, GHS is a hazard communication model that combines best practices from the leading chemical information systems around the world into a single system that can be adopted by countries and other jurisdictions.
Today over 43 million workers in over 5 million workplaces are covered by the HazCom Standard, which means OSHA’s adoption of GHS creates compliance issues that extend far and wide into American workplaces, especially industrial facilities. The biggest changes that companies in the United States will see thanks to GHS adoption are to chemical classification, labels and safety data sheets.
Note: OSHA refers to the HazCom Standard post-GHS adoption as HazCom 2012. It refers to the HazCom Standard pre-GHS adoption as HazCom 1994. Both of these terms will be used throughout the three part series.
To Understand GHS, First Understand the HCS
The HazCom Standard identifies three main groups involved in the lifecycle of a hazardous chemical. For those three groups, HazCom 1994 set out the following compliance responsibilities:
Chemical Manufacturers must evaluate the hazards of chemicals and communicate information about those hazards to downstream users via labels and safety data sheets
Importers & Distributors must provide labels and safety data sheets to downstream users
Employers must meet five key responsibilities: 1) maintain a workplace specific written Hazard Communication Plan; 2) maintain a written inventory of all hazardous chemicals present in the workplace; 3) ensure the proper use of labels and warnings; 4) maintain safety data sheets for every chemical listed on the written chemical inventory and make them readily available to employees; 5) train employees on the basics of the HazCom Standard and the specific hazards of the chemicals to which they are exposed.
For decades, OSHA left it up to chemical manufacturers and distributors to determine how to evaluate chemical hazards and how best to communicate those hazards. This approach resulted in a marketplace where chemicals – even those with nearly identical properties – had very different safety information listed on the labels and safety data sheets.
Under HazCom 2012, the core responsibilities remain intact; however, the standard loses its classification ambiguity and is replaced with specific criteria and instructions for defining chemical hazards and communicating those hazards via labels and safety data sheets using precise language, elements and formatting. To achieve this level of specificity, chemical manufacturers, distributors and employers are tasked with a number of tasks during the transition period.
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