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We have been reading for some time about the impact of Global Harmonization on OSHA’s Hazard Communication Rule. In brief, the Global Harmonization System (GHS) is an international approach to harmonize international efforts related to the environmentally sound management of chemicals. GHS principles are not standards, but rather guidelines for individual countries to use in developing new regulations regarding chemical management. So, if you are doing business internationally, be advised: the rules will still vary, depending on whether you are doing business in the EU, Asia or elsewhere.
Here in the United States OSHA revised their Hazard Communication Rule to conform to many of the GHS recommendations, effective May 2012. There were many revisions to the requirements, but the biggest impact of the changes was twofold:
- Harmonized criteria for the classification of substances and mixtures according to their physical, health and environmental hazards; and
- Harmonized hazard communication elements, including requirements for labels and safety data sheets.
All chemicals are now required to be classified by the manufacturer with respect to their physical and health hazards. That information must be communicated to downstream users through data sheets and labels. Material Safety Data Sheets (now called Safety Data Sheets – SDS) are required to be in a standardized sixteen section format. Labeling has undergone radical changes, with requirements for standardized pictograms, signal words and hazard statements.
The first deadline of the new requirements is fast approaching. Employers are required to have trained employees on the new elements of labels and SDS by December 1, 2013. Hazard Communication compliance is a key element of OSHA enforcement, and fines for willful violation of training requirements can reach $7,000 per employee.
Employee training will be a key factor in the success of your organization’s implementation of GHS. If you haven’t taken the time to revise your written Hazard Communication Program, now is the time to do it. And make sure that your employees have met the training requirements prior to the deadline of December 1 – that’s only two months away!