In October 1999, the United Nations Economic and Social Council decided to enlarge the mandate of the Committee of Experts on the Transport of Dangerous Goods by reconfiguring it into a Committee of Experts on the Transport of Dangerous Goods and on the Globally Harmonized System of Classification and labelling of Chemicals. 14 plus years later, OSHA revised the Hazard Communication Standard to ensure that employers train workers exposed to hazardous chemicals on the big changes the update brings to labels and safety data sheets and to eventually conform to these international standards.
OSHA has provided compliance information on its website and information can be found in the Federal Register. However, Management and Safety personnel still have some questions on how this all will be implemented and what they may need to do to ensure compliance.
Most of the requirements that employers had been complying with are still key components to the new system. If you are in charge of your Hazard Communication compliance, you need to continue to do the following:
Chemical manufacturers and distributors are responsible for sending updated documents to the end users of their chemicals with the first shipment or the next shipment after a change has been made. This may cause employers headaches as their updates may be dependent on how quickly manufacturers and distributors update their safety data sheets. Also, manufacturers will likely not be required to send additional updates to their SDS so staying on top of these changes and having a system in place to ensure compliance will be key to success and compliance.
Labels under the old system allowed for chemical manufacturers and distributors to use discretion as to what to put on the label. OSHA would then determine whether the label was compliant based on how well it performed in the workplace.
Under the new standard, label information is must meet the following six elements per OSHA:
OSHA explicitly allows employers to continue to use their current workplace labeling systems so long as they effectively communicate to employees the hazards of the chemicals to which the workers are exposed. Employers can either provide all of the required information that is on the label from the chemical manufacturer, or the product identifier and words, pictures, symbols or a combination thereof. This would allow for employers to develop their own system of on-site labeling as long as it performs within the established guidelines set forth by OSHA.
The most basic of change is the name change to safety data sheets or SDSs, which dropped the M from MSDS. These new SDS sheets will have a 16 section format to make safety data sheets even more standardized and easier to read and disseminate information quickly and efficiently. At a minimum, SDS sheets must include the following information in order from 1-16:
"Globally Harmonized System of Classification and Labelling of Chemicals - GHS." Globally Harmonized System of Classification and Labelling of Chemicals - GHS. N.p., n.d. Web. 25 Oct. 2014