Think You Know HazCom?

Safety professionals have long had concerns with MSDSs, beginning with issues about the ability of workers to understand them.

• By Robert A. Ernst
• Oct 01, 2010

A typical American workplace can have any number of hazardous chemicals to which workers may be exposed. The Occupational Safety and Health Administration estimates there are as many as 650,000 hazardous chemicals, defined as those that present a physical or health hazard, in use in more than 3 million U.S. workplaces, putting millions of workers at risk for possible exposures.

Under OSHA's Hazard Communication Standard (HazCom), manufacturers, importers, and distributors of hazardous chemicals are required to determine the hazards of the chemical(s) they produce or import and provide that information downstream. Employers must provide workers access to information about the chemicals in the workplace through comprehensive hazard communication programs, which include container labeling and other forms of warning covered under 29 CFR 1910.1200(f).

HazCom is based on a simple concept -- that employees have both a need and a right to know the identities and hazards of the chemicals to which they are exposed at work. And there are three primary ways HazCom requires that information be provided: through the material safety data sheet (MSDS), the container label, and training.

The current HazCom requirements have been in effect since 1994. OSHA has proposed significant changes to HazCom that are likely to affect each of these requirements. The HazCom you thought you knew will be changing.

Globally Harmonized System
In September 2009, OSHA published a proposal to align HazCom with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). OSHA believes aligning with the GHS will increase the quality and consistency of safety information by adopting a standardized approach to hazard classification, container labels, and safety data.

Under the current HCS, chemical manufacturers and importers must evaluate chemicals and report hazard and safety information to "downstream" users using container labels and MSDSs. That responsibility will not change, nor will adoption of the GHS change the framework and scope of HazCom. However, adoption of the GHS will affect other portions of the regulation.

Safety Data Sheets
Under the existing HCS, MSDSs are allowed to be in any format as long as they are in English and the following information appears:

• Specific chemical identity and common names
• The chemical's physical and chemical characteristics
• Potential acute and chronic health effects and related health information
• Whether the chemical is considered to be a carcinogen
• Exposure limits
• Recommendations for appropriate protective measures
• Emergency and first aid procedures

Safety professionals have long had concerns with MSDSs, beginning with issues about the ability of workers to understand them. Without guidelines on content, MSDSs could lack completeness or include technical data that is not intended for the end user.

Following adoption of the GHS, employers will notice significant changes in MSDSs. Gone will be the familiar MSDS, in favor of the preferred term "Safety Data Sheet," or SDS.

The updated HCS will require the use of the GHS-style, 16-section SDS format, which includes:

1. Product and company identification
2. Hazards identification
3. Composition/information on ingredients
4. First aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection biological limit values
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

Items of interest to workers are presented at the front of the document, while more technical information is presented later. Headings for the sections (e.g., First Aid Measures, Handling & Storage) are standardized to make it easier to locate the desired information.

The other duties and responsibilities for providing and transmitting SDSs, or making them available to employees, will not change.

Labels
OSHA currently requires that each container of a hazardous chemical in the workplace be labeled, tagged, or marked with:

1. The identity of the chemical, and
2. Appropriate physical and health warnings for the chemical.

HazCom doesn't specify what the label must look like or what are considered to be appropriate warnings. The standard does, however, require that labels be readable and in English.

Adoption of the GHS will require chemical manufacturers and importers to label containers of hazardous materials with a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements also must be included. The GHS uses nine pictograms to convey the health, physical, and environmental hazards. HazCom can require only eight of these pictograms, the exception being the environmental pictogram because environmental hazards are not under OSHA's jurisdiction.

Employers still will be able to use traditional in-house labeling systems, such as Hazardous Materials Identification System (HMIS®) and National Fire Protection Association (NFPA), but only on containers that won't leave the facility. Adoption of GHS will not affect local fire code requirements to placard outside tanks or the exterior of buildings with NFPA diamonds.

Training
Information and training are a critical part of your HazCom program. Workers are provided information regarding chemical hazards and protective measures from container labels and SDSs. Training is essential to ensure that workers understand the information provided, where they can get more information, and how they can use the information to protect themselves. An employer's training responsibilities will not change when HazCom is updated.

Training is not covered in the GHS, even though it is required under HazCom. However, the proposed HCS will require that workers are trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safety data sheets.

Conclusion
MSDSs, labels, and training together provide a complete approach to hazard communication that ensures required chemical information is provided in a way that reinforces and explains it to those exposed. The expected changes to the HazCom rule should make the information more uniform and more readily available to all who rely on it to keep themselves, and others, safe. Expect to see OSHA publish a final rule soon.

And while we can expect to see some interesting changes when the proposed rule is adopted, don't worry: Much of your existing knowledge about the HazCom standard will still apply.