Safetec – As you know, OSHA’s revisions to its Hazard Communication Standard (HazCom) to incorporate certain aspects of GHS has been a long time coming. However, we are in the final stages, as it passed review at the Federal Office of Management and Budget on February 21, 2012.

Let’s review the major changes and challenges on the horizon with respect to the new HazCom Standard:

Major Changes:

1. Hazard Classifications

OSHA definitions have changed to accommodate the new GHS hazard classifications. OSHA previously referred to these as “hazard determinations.” With the new HazCom standard, we will need to comply with the GHS criteria based standards for 12 health hazard classifications and 16 physical hazard classifications. 

Additionally, GHS adds severity rankings to each of the hazard classifications. Categories range from 1 to 4; with “1” indicating the most severe and “4” indicating least severe. 

2. Pictograms

OSHA will adopt the 8 pictograms per the GHS guidance. These pictograms are meant to visually convey the health or physical hazard present. Pictograms will need to be on every label and safety data sheet 

3. Material Safety Data Sheets

Material Safety Data Sheets will become Safety Data Sheets (SDS), per GHS guidance. Each SDS will need to be in a uniform 16 section format. The required elements for each section are detailed in the new HazCom Standard. ALL active MSDS will need to be converted to the SDS format. Archieved MSDS do not need to be converted. HazCom will still require a 30-year SDS retention. All MSDS will need to be converted to the new SDS format within 3 years of the promulgation date of the new HazCom standard.

4. Labeling

Labels will be required to follow a uniform format containing 9 elements: product name/identifier; a symbol (pictogram); signal words; hazard statement; supplemental information; precautionary measures; first aid information; company information; and company telephone number.

Major Challenges:

NFPA, HMIS, GHS

Most of us are used to the NFPA and HMIS systems where the number “4” indicates a severe hazard. However, under the new GHS HazCom standard, a “4” will mean the least severe and “1” will mean the most severe.

Most of us in the regulated community are very concerned that this will be the source of great confusion on the manufacturing floor and that this will be an extremely difficult training scenario, as all police, fire departments and other emergency responders are trained in the NFPA and HMIS systems.

 Here is what OSHA said during the public comment period for the new HazCom standard:

 ”OSHA recognizes that the approach to numbering hazard categories in the GHS differs from that used in the HMIS and NFPA systems. However, the Agency does not believe that this will result in confusion. GHS category\numbers determine the label elements that would be required for a chemical, but the category numbers themselves would not appear on labels. Where GHS category numbers would appear on the SDS (Section 2–Hazards identification), they would be accompanied by the label elements for the chemical, which would clearly indicate the degree of hazard. OSHA, therefore, does not anticipate that this information will cause employees to become confused. Moreover, the approach taken in the GHS (i.e., assigning higher category numbers to denote less serious hazards) is consistent with the approach used in the DOT transport regulations for many years.”