OSHA Harmonization Could Be Costly


These changes are significant, and the cost of compliance could run in the low- to mid-six figures. This was the sobering conclusion of Jeff Leiter, general counsel of the Petroleum Packaging Council, on the OSHA rule to harmonize its Hazard Communications Standard with the Globally Harmonized System (GHS).

Speaking at PPCs fall meeting in Charleston, S.C., Leiter noted that the costs include software and system upgrades needed to manage the changes, as well as the time involved in updating product safety data sheets (SDSs), and tracking SDSs from suppliers.

OSHA issued a final rule in March 2012 to align its Hazard Communication Standard with the GHS. The new standard still requires chemical manufacturers and importers to evaluate the chemicals they produce or import and provide hazard information to employers and workers by labeling containers and preparing safety data sheets.

However, the old standard allowed them to convey hazard information in whatever format they chose. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets.

Its important to understand all thats required to implement these changes, he said. Who will author all these SDSs? Who will manage SDSs coming in from vendors? Can your label makers incorporate all the information thats now required on all the various package sizes you produce?

His message was clear. If you think you have a lot of time, think again! Although the first deadline doesnt arrive until December 1, 2013, a lot of work has to be done in the meantime.

By that date, companies must train employees on the new GHS rule. Largely, it is to walk them through the elements of the rule and inform them of the differences between GHS and the existing Hazards Communications Rule, said Leiter. Also, companies must explain the chemical hazards workers will deal with as identified on the new data sheets as well as the pictograms they will see on the new labels.

Labeling and SDS requirements kick in on June 1, 2015. OSHA will embrace the new 16-part sheet but enforce only 12 sections. The new signal words that will be required on labels must be explained to workers, said Leiter, along with the new SDS, the order of sections, what theyll find in each section, and measures they can take to protect themselves.

The largest and most significant change to labels is the use of standard hazard pictograms, Leiter said. Signal words must also be part of the labels as well as standard wording for hazard statements. Leiter added that its important to understand the kind of changes to label designs that are going to be necessary to fit all this information on the various size containers used in industry.

Distributors have until December 1, 2015, to get their SDSs and labels in place. Finally, some alternative workplace labeling and advanced training must be completed by January 1, 2016.

The GHS is currently in place in Asia and the European Union, and the U.N. website gives a very good summary of the specific requirements with respect to labeling in all these countries, added Leiter. One thing I would point out, though, is if youre sending something to South Korea, your label will be different from that for a product going to the EU. So, rather than being harmonized, theres still some dysfunction in the program.

Other U.S. agencies are involved with implementing GHS. The Environmental Protection Agency, for example is looking at pesticides. The Consumer Product Safety Commission also has some authority with respect to the labeling of chronic health hazards in the consumer product setting. The Commission has laid out a plan to implement GHS, although they have yet to do so. Finally, the Department of Transportation has already implemented the pictograms that will be required on placarding for over the road vehicles.

A lot of webinars and seminars are available to help you understand all thats involved in implementing the new rule, Leiter said. Its a good idea to get started now.

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