HazCom Trained Yet?

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As OSHAs Dec. 1 deadline for training looms, U.S. employers have just two more months to ensure employees are familiar with the new Globally Harmonized System of hazardous material communication standards.

The key thing for revised OSHA HazCom compliance in 2013 is the obligation for employers to train all employees on the new labeling elements and data sheets by the end of this year, the Petroleum Packing Councils general counsel Jeff Leiter reminded the council at its fall meeting in Nashville, Tenn.

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More commonly known as HCS 2012, or the GHS ruling, the standard aims to bring U.S. workplaces and products into conformance with the internationally adopted Globally Harmonized System of Classification and Labeling of Chemicals. Implementation of the GHS ruling involves not only the U.S. Occupational Safety and Health Administration, but also several other federal agencies, each with its own objectives.

On this first phase of its move to GHS standards, OSHA is calling specifically for workers to be acquainted with the new label requirements, which aim to improve understanding of hazards associated with chemicals in the workplace and to shine light on newlyidentified physical and health hazards. The amended label requirements include product identifiers, signal words, pictograms, hazard statements, and contact information for the contents chemical manufacturer, distributor, or importer. Employees must also become accustomed to a new format for safety data sheets (SDSs), which were formerly known as material safety data sheets (MSDSs).

With the deadline around the corner, timing is just one of the challenges managers face in effecting the requirements. Some companies are already receiving the new, updated safety data sheets from vendors and suppliers, Leiter said. Employers need to train employees on how to read those new sheets while theyre still dealing with other vendors that are giving out the old MSDSs.

Scope is another complication Leiter identified. Those in charge of training workers must realize that as the hazard communication rules are standardized to fit the global format, different sections of the 16-section SDS will be applicable to different regions of the world, Leiter remarked. To the extent that you sell products overseas, the difference in the new format is that youll at times need to comply with REACH [the European Unions Registration, Evaluation, Authorization and Restriction of Chemicals regulation], or other country-specific GHS requirements.

Perhaps the biggest challenge, Leiter pointed out, is the label itself. Folks are telling me they are having issues with the labeling requirements – specifically, the pictograms. Different labels for the same product may cause confusion, Leiter said, adding that its important for those doing the training to be cognizant of the differences between GHS and other regulations such as those enforced by the National Fire Protection Agency, the Workplace Hazardous Materials Information System, the U.S. Department of Transportation and the Consumer Product Safety Commission. The new GHS data sheets will have classification numbers unlike in-use NFPA labels, and the pictograms will be different than those used in DOT, Leiter noted. The new classification system is more complicated, and some employees may need assistance with decision-making.

The bottom line of all this is that with these challenges, theres going to need to be a lot more thinking as to how to train these employers between now and the end of the year, Leiter concluded. Online PowerPoint classes, posters in work areas, badge cards for employees to carry, and newsletters delivered to employees are some of the tools that employers are relying on to disseminate the necessary information in time, Leiter said.

Leiter, senior partner with Washington, D.C.-based Leiter & Cramer PLLC, is general counsel to both PPC and the Independent Lubricant Manufacturers Association.

OSHAs Hazard Communication website (www.osha.gov/hazcom) includes additional training material to assist employers with the training requirements.