With the first compliance date effective December 1, 2013; the revised HCS is now in enforcement. What does this mean for employers? Employers are required to have their employees trained on the new label elements and the SDS format. This deadline is the first phase in the new compliance set forth when OSHA revised its Hazard Communication Standard to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals or GHS.

This revision includes two major changes; being the required use of new labeling elements and a standardized format for Safety Data Sheets replacing Material Safety Data Sheets. These changes were set forth to improve worker understanding of the hazards associated with the chemicals present in their workplace. OSHA has phased the new requirements in from December 2013 through June 2016.

The minimum required training topics to be completed by December 1, 2013 according to OSHA’s website include:

Training on label elements including information on:

• Type of information the employee would expect to see on the new labels, including the

1. Product identifier: how the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS (Identification).
2. Signal word: used to indicate the relative level of severity of hazard and alert the
   reader to a potential hazard on the label. There are only two signal words, “Danger” and “Warning.” Within a specific hazard class, “Danger” is used for the more severe
   hazards and “Warning” is used for the less severe hazards. There will only be one
   signal word on the label no matter how many hazards a chemical may have. If one
   of the hazards warrants a “Danger” signal word and another warrants the signal word
   “Warning,” then only “Danger” should appear on the label.
3. Pictogram: OSHA’s required pictograms must be in the shape of a square set at a
   point and include a black hazard symbol on a white background with a red frame
   sufficiently wide enough to be clearly visible. A square red frame set at a point
   without a hazard symbol is not a pictogram and is not permitted on the label. OSHA
   has designated eight pictograms under this standard for application to a hazard
   category.  OSHA3491QuickCardPictogram
4. Hazard statement(s): describe the nature of the hazard(s) of a chemical, including,
   where appropriate, the degree of hazard. For example: “Causes damage to kidneys
   through prolonged or repeated exposure when absorbed through the skin.” All of the applicable hazard statements must appear on the label. Hazard statements may
   be combined where appropriate to reduce redundancies and improve readability. The
   hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it.
5. Precautionary statement(s): means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.
6. Name, address and phone number of the chemical manufacturer, distributor, or importer.

• How an employee might use the labels in the workplace. For example:

1. Explain how information on the label can be used to ensure proper storage of hazardous chemicals.
2. Explain how the information on the label might be used to quickly locate information
   on first aid when needed by employees or emergency personnel.

• General understanding of how the elements work together on a label. For example:

1. Explain that where a chemical has multiple hazards, different pictograms are used to
   identify the various hazards. The employee should expect to see the appropriate
   pictogram for the corresponding hazard class.
2. Explain that when there are similar precautionary statements, the one providing
   the most protective information will be included on the label.

Training on the format of the SDS must include information on:

•  Standardized 16-section format, including the type of information found in the various sections.

1. For example, the employee should be instructed that with the new format, Section 8 (Exposure Controls/Personal Protection) will always contain information about
   exposure limits, engineering controls and ways to protect yourself, including personal protective equipment.

• How the information on the label is related to the SDS.

1. For example, explain that the precautionary statements would be the same on the label and on the SDS.

For more information on the revisions visit OSHA’s website here.

Want to learn more about how you can gain access to Trillium’s national network of top level talent? Contact us today!  If you are a stand out in your profession and seeking contingent or long term career opportunities, visit our job seekers section for more information!

Trillium, a national leader in staffing and recruitment is a valued staffing partner to over 5,000 companies nationwide. Trillium is privately owned by Oskar René Poch.