By: Matt McCreery

November 2014

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.

#1 Maintain Compliance with the “old” Hazard Communication Standard

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:

  • Have a written hazard communication program
  • Continue to track and archive a list of hazardous chemicals present in the workplace and have a system for new chemicals that may be introduced
  • Maintain safety data sheets for all hazardous chemicals and provide Right-To-Know access to your personnel
  • Ensure proper use of labels and warning signs in the workplace
  • Continue to hold annual training for your personnel on Hazard Communication and any updates that you or your company have implemented.

#2 Stay on top of Labels and SDS Changes

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.

Label Changes

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:

  1. Product Identifier -- Same product identifier as found on safety data sheet
  2. Supplier Information -- Including name, address, and phone number of responsible party
  3. Pictogram(s) -- Black hazard symbol on white background with red diamond border
  4. Signal Word -- Must use either "Danger" or "Warning," depending upon hazards
  5. Hazard Statement(s) -- Declarative statement regarding nature or degree of hazard
  6. Precautionary Statement(s) -- Descriptions of appropriate prevention, storage, response, and spill measures

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.

MSDS Changes

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:

  1. Product and Company Identification
  2. Hazard Identification
  3. Composition / Information On Ingredients
  4. First Aid Measures
  5. Fire Fighting Measures
  6. Accidental Release Measures
  7. Handling and Storage
  8. Exposure Control / Personal Protection
  9. Physical and Chemical Properties
  10. Stability and Reactivity
  11. Toxicological Information
  12. Ecological Information
  13. Disposal Considerations
  14. Transport Information
  15. Regulatory Information
  16. Other Information



"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