The Occupational Safety and Health Administration (OSHA) published its new Hazard Communication Standard in March 2012, which resulted in numerous changes. Now, with the final June 1, 2016 deadline quickly approaching, it is time to make sure you’re in full compliance.
Why the Update?
If this is the first you’re hearing about the final rule (it shouldn’t be) on this standard, here’s a quick rundown on the background behind it.
In an effort to continue improving the safety and health of workers in the United States, OSHA’s goal is to better align its Hazard Communication Standard with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Given the success of the current standard, the GHS is expected to help save lives, prevent injuries, and improve chemical manufacturing trade conditions by helping workers better understand the items they’re working with.
In order to do this, numerous changes were made, including changes in the way chemical hazards are classified, the labeling of chemicals, the way employees are trained, and the replacement of Material Safety Data Sheets (MSDS) with Safety Data Sheets (SDS).
What Happens on June 1, 2016?
Simply put, when June 1 rolls around, you must be in full compliance with the Hazard Communication Standard.
What Important Items Do You Need to Remember?
In order to fully comply with the updated Hazard Communication Standard, there are some steps you should take (if you haven’t already), including: preparing and implementing a hazard communication plan, ensuring all containers are labeled, maintaining safety data sheets, retraining all employees, labeling secondary containers, and evaluating your program.
Let’s look more closely at these steps.
Preparing & Implementing Your Hazard Communication Plan
You should already have a hazard communication program in writing, but you’ll want to spend time updating and implementing this plan so that it matches the new standards. Don’t forget, unless you’re a lab or your employees only handle chemicals in sealed containers, you must have a written plan.
While this plan doesn’t need to be complicated, it absolutely must provide information on which hazardous chemicals are present in your work environment. Other important things that should be covered are a general description on how hazard communication will occur and procedures informing employees about the hazards of performing infrequent, non-routine jobs.
Having a quality communication plan in place helps assure that you and your employees understand the risks associated with certain materials and how they can help mitigate those risks to both themselves and others.
Ensure Safety Data Sheets (SDSs) Are Readily Available & Maintained Properly
Safety data sheets contain vital information regarding the hazards of a chemical and should be made readily available throughout your entire workplace. Additionally, you should have an SDS for each hazardous chemical in your facility.
In addition to providing access to these throughout your physical location, it’s a good idea to provide them to anyone working remotely or anyone in the field (e.g. truck drivers).
It’s also vital to maintain safety data sheets and update them whenever necessary.
Train or Retrain Employees on Workplace Hazardous Chemicals
Perhaps it’s common sense, but OSHA requires the employer to train (or retrain) all employees in regards to the hazards of the chemicals they’ll be working with.
“Paragraph (h) of the HCS requires that employers train employees on the hazardous chemicals in their work area before their initial assignment and when new hazards are introduced into the work area, and this training must be conducted in a manner and language that employees can understand. Workers must understand they are exposed to hazardous chemicals. They must know that labels and safety data sheets can provide them with information on the hazards of a chemical, and these items should be consulted when needed. In addition, workers must have a general understanding of what information is provided on labels and SDSs, and how to access them. They must also be aware of the protective measures available in their workplace, how to use or implement these measures, and whom they should contact is an issue arises.”
Ensure Compliance Through Proper Labeling
Whether it’s labeling all of your secondary containers or simply just using industrial grade labels that don’t degrade in harsh environments, making sure your chemicals are labeled in accordance to the GHS is an important step in the journey to becoming fully compliant.
Labels must be kept in place at all times and, in the event they become damaged or illegible, must be replaced. At the minimum, each label must have a product identifier and general information about any hazards associated with it.
Per OSHA, for workplace chemicals, your program should include the following information in terms of labeling: identity of the individual in charge of making sure everything is labeled, provide information on the system you have in place for labeling containers, and highlight any alternatives for labeling containers.
For containers that are shipped to your facility, OSHA suggests identifying the individual in charge of making sure those containers are labeled properly and describing the labeling system used to make GHS labels for shipments from your facility.
Evaluate What You Have in Place
After you’ve taken the time to ensure you have an adequate hazard communication plan in place, it’s equally as important to sit down and evaluate it periodically. The plan must remain current and if any updates occur in your workplace, or new chemicals are introduced, you need to account for that in your plan. In doing so, you’ll ensure that you’re well on the way to becoming fully compliant with the Hazard Communication Standard.