Is Your Company Prepared for OSHA’s Revised Hazard Communication Standard?

Chemical Industry Update

Date: April 03, 2012

Introduction

On March 20, 2012, the Occupational Safety and Health Administration (OSHA) released a final rule modifying its current Hazard Communication Standard (29 CFR. 1910.1200) (HCS) to comport with the United Nations' Globally Harmonized System of Classification and Labelling of Chemicals. Modifications to the standard include revised criteria for classification of chemical hazards; revised labeling provisions that include requirements for use of standardized signal words, pictograms, hazard statements, and precautionary statements; a specified form for safety data sheets; revised definitions of terms used in the standard; and requirements for employee training on the revised labels and safety data sheets discussed above.

Overview

The revisions to the HCS will primarily affect manufacturers and importers of hazardous chemicals. Pursuant to the final rule, chemical manufacturers and importers must re-evaluate chemicals according to new criteria in order to ensure that the chemicals are appropriately classified. For health hazards, this entails assigning the hazard to an appropriate hazard category and subcategory (hazard class). For physical hazards, the new criteria are generally consistent with current DOT requirements; therefore, if chemicals are already properly classified under DOT requirements, minimal work is required to classify physical hazards. The new classification criteria will result in chemicals being classified by type, degree, and severity of the hazards posed.

The revisions to the HCS include 10 health hazard categories and 16 physical hazard categories. The health hazard categories are:

  • Acute toxicity
  • Skin corrosion or irritation
  • Serious eye damage or eye irritation
  • Respiratory or skin sensitization
  • Germ cell mutagenicity
  • Carcinogenicity
  • Reproductive toxicity
  • Specific target organ toxicity through single exposure
  • Specific target organ toxicity through repeated exposure
  • Aspiration hazards

The physical hazard categories are:

  • Explosives
  • Flammable aerosols
  • Oxidizing gases
  • Gases under pressure
  • Flammable liquids
  • Flammable solids
  • Self-reactive chemicals
  • Pyrophoric liquids
  • Pyrophoric solids
  • Self-heating chemicals
  • Chemicals in contact with water
  • Chemicals that emit flammable gases
  • Oxidizing liquids
  • Oxidizing solids
  • Organic peroxides
  • Corrosive to metals
Examples of Specific Revisions

Examples of specific changes to the current HCS include:

  • Labels. The revised HCS will require the use of red, rather than black, borders around pictograms for labels used in domestic commerce to make the pictograms more noticeable. Labels also must include a signal-word hazard statement, relevant hazard statements, pictograms, and precautionary statements. In some instances, OSHA concluded that specific precautionary statements about certain substances might not be appropriate on a label. If a manufacturer, importer, or responsible party can show that a particular statement is inappropriate for a product, that precautionary statement may be omitted from the label.
  • Hazard classification. Hazard classification will be governed by including the International Agency for Research on Cancer and the National Toxicology Program as resources for determining whether a chemical should be classified as a carcinogen.
  • Unclassified hazards. Unclassified hazards will be renamed as "hazards not otherwise classified." OSHA has removed pyrophoric gases, simple asphyxiants, and combustible dust from the general definition of hazards not currently classified. OSHA has instead added definitions for pyrophoric gases and simple asphyxiants and provided guidance on defining combustible dust for purposes of complying with the HCS.
  • Safety data sheets. Manufacturers and importers of chemicals also will be required to prepare and distribute modified labels and safety data sheets. Safety data sheets must have 16 sections covering areas such as substance identification, hazard identification, first-aid measures, and physical and chemical properties. Manufacturers and importers following the ANSI Z400.1 standards for safety data sheets already should be using the appropriate format; thus, only minor content changes will be required to comply with the revised HCS.
When Will the Revised HCS Go Into Effect?

The revised HCS will go into effect on a staggered basis. Employers must train workers on the new labeling and safety data sheet requirements by December 1, 2013. By June 15, 2015, chemical manufacturers, importers, distributors, and employers must comply with all provisions of the revised HCS. As of December 1, 2015, distributors shall not ship containers labeled by chemical manufacturers unless the containers comply with the revised HCS labeling requirements.