OSHA HCS 2012 required employers to train their employees on the new GHS label elements and Safety Data Sheet format by December 1, 2013. This training applies to ALL US employers, including wholesalers, distributors and manufacturers, whose employees and chemical users may be exposed to hazardous chemicals.
Safety Data Sheets
The revised HCS requires manufacturer SDSs follow a uniform format, including section numbers, named headings, and associated information. Since May 2012, an increasing number of chemical manufacturers and distributors have begun to ship their products with SDSs that conform to the revised HCS. As such, it is critical that employers train their workers on the GHS elements and new SDS format soon. Chemical users should feel free to ask questions on the GHS label elements and SDSs to ensure their comprehension and understanding. Simply providing materials for them to read is insufficient.
OSHA HCS 2012 Labels
Under OSHA HCS 2012, chemical manufacturers and importers must label their chemical containers with the applicable GHS elements. In turn, employers must convey these GHS elements on the workplace label for each hazardous chemical. These GHS elements include:
- Signal Word: “Danger” or “Warning” indicates the severity of the hazard.
- GHS Pictograms: convey the health, physical and environmental hazard information assigned to a specified GHS hazard class and category.
- Health and Physical Hazard Statements: describe the nature and degree of the stated hazard.
- Precautionary Statements: describe measures to minimize or prevent effects from exposure or improper storage of the hazardous chemical.
Hazard Communication Standard Pictograms and Hazards
As of June 1, 2015, the Hazard Communication Standard (HCS) requires pictograms on labels to alert users of the chemical hazards to which they can be exposed. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s). The pictogram on the label is determined by the chemical hazard classification.
OSHA HCS 2012 – Key Dates
Checklist for Compliance
Employers must ensure the most current supplier SDS for each chemical product used in the workplace is available to their employees and chemical users. Do NOT presume chemicals previously considered “non-hazardous” by the manufacturer remain so under OSHA HCS 2012.
Use the following checklist to help you comply with OSHA HCS 2012:
- Audit your chemicals: conduct a physical audit of all chemicals in the workplace
- Confirm the use of workplace labels: as you conduct your inventory, ensure all containers are properly labeled
- Obtain updated supplier SDSs: contact the manufacturer for a current SDS for each chemical in the workplace
- Distribute your supplier SDSs: ensure your chemical users have FREE, unlimited access to the updated SDSs
- Train your employees: update your existing hazardous chemical training program to include the GHS data elements and format of the SDS
The underlying purpose of OSHA Hazard Communication Standard 2012 is to reduce the incidence of injuries and illnesses. A better understanding of chemical hazards in the workplace will help reduce risks due to chemical exposure.