New OSHA Regulations
Hazard Communication Standard conforms with Globally Harmonized System
With the June 1st deadline in sight, Hubbard-Hall is well prepared for compliance with OSHA’s revised Hazard Communication Standard (HCS) requirements. We have converted over 600 of our material safety data sheets (MSDS) into safety data sheets (SDS) and have been labeling under the new format for the past month.
A few things for our customers to note: all Hubbard-Hall products stored in our warehouses will be shipped with the new labeling and SDS effective June 1st. As a distributor, Hubbard-Hall will comply with the December 1st deadline for products that are purchased from other producers/manufacturers and resold by Hubbard-Hall.
Read below to understand why the HCS is changing, what the changes will look like and the important dates you need to know. You can also click here to review the 25 frequently asked questions about the modifications of the HCS.
Why is the Hazard Communication Standard changing?
Changes to the HCS are being implemented by OSHA to conform with the United Nations’ (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS created new requirements for classifying, labeling and creating safety data sheets (SDS) for hazardous chemicals in the workplace.
Dr. David Michael, Assistant Secretary of Labor for Occupational Safety and Health, states that “this update to the Hazard Communication Standard will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets”.
What will the changes look like?
The 3 major areas of change include labels, safety data sheets, and hazard classification.
- Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. The HCS requires eight pictograms, the exception being the environmental pictogram, environmental hazards are not within OSHA’s jurisdiction. The hazard pictograms and their corresponding hazards are shown below:
- Safety Data Sheets: Safety data sheets (SDS) will replace material safety data sheets (MSDS). The SDS format includes 16 specified sections:
Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-Aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical properties
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information
Section 13. Disposal considerations
Section 14. Transport information
Section 15. Regulatory information
Section 16. Other information, including date of preparation or last revision
- Hazard classification: Changes to the definitions of hazards will provide precise criteria for the classification of health and physical hazards, as well as the classification of mixtures. These specific criteria will ensure that evaluations of hazardous effects are consistent across manufacturers and that labels and safety data sheets are more accurate.
What is the phase-in period?
The table below summarizes the phase-in dates that were set under the revised HCS:
|Effective Completion Date||Requirement(s)||Who|
|December 1, 2013||Train employees on the new label elements and safety data sheet (SDS) format.||Employers|
|June 1, 2015*December 1, 2015||Compliance with all modified provisions of this final rule, except: The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label.||Chemical manufacturers, importers, distributors and employers|
|June 1, 2016||Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.||Employers|
|Transition period to the effective completion dates noted above.||May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both.||Chemical manufacturers, importers, distributors, and employers|
*This date coincides with the EU implementation date for classification of mixtures.