Q. Our metal finishing facility has an existing Hazard Communication (HazCom) Program in place based on OSHA’s general industry standard 29 CFR 1910.1200. Our program has been in place for many years with minor revisions made once every four to five years.
As with most metal finishing and plating shops, the hazards of most concern involve alkalis, acids, oxidizers, metal containing solutions, and dust from grinding and polishing. Over the last year, we have received several correspondences regarding OSHA’s proposal to modify the existing HazCom Standard to conform to the UN Globally Harmonized System (GHS) of classification and labeling. Could you provide me with an update on this proposal and a process a metal finishing shop could follow in meeting the GHS when approved? L.B.
A. OSHA’s HazCom standard has been around since Nov. 25, 1983, and is designed to protect more than 30 million American workers exposed to hazardous chemicals in their workplaces. The standard’s main elements include having the following in place: 1)Written Program, 2)Material Safety Data Sheets (MSDSs), 3)Chemical Inventory, 3)Labeling, and 4)Employee Training.
As the world has become smaller with shipments of chemicals and products received from all corners of the globe daily, there is a need for standardization. In 2003, the United Nations created and adopted the Globally Harmonized System of Classification and Labeling of Chemicals. The GHS includes criteria for the classification of health, physical and environmental hazards, labeling, and safety data sheets.
Since the 2003 publishing of the GHS by the UN, OSHA has been in the process of revising its Hazard Communication Standard to be more consistent with the GHS.
OSHA published a notice of proposed rule-making on Sept. 30, 2009 to align OSHA's Hazard Communication standard with the GHS. The following are dates of significant past and future developments as related to OSHA’s progress:
- December 2009: Public Comment Period Ends
- March/April 2010: Informal Public Hearings
- 2011: Expected Proposed and Final Rule
- 2011–2014: Expected Transition for GHS Adoption
As stated above, OSHA expects to adopt a revised Hazard Communication Standard that includes information included in the GHS in 2011. Once the rule is finalized, employers will have three years to implement the new standard. The most significant impacts upon employers include:
Safety Data Sheets (SDS). The current material safety data sheets (MSDSs) will become SDSs. The new SDSs, that are required to be developed by chemical suppliers and importers, will have a more standardized format (16 Sections). The stated goal of the consistent format is to assist employees in more quickly and easily finding the information they need. Of the 16 sections, there are four sections not currently required on MSDSs: Ecological Information, Disposal Considerations, Transport Information, and Regulatory Information.
Container Labeling. The Hazardous Materials Identification System (HMIS), National Fire Protection Association (NFPA) or other labels currently used will be replaced. Manufacturers and importers will be required to provide a label that includes signal words (Flammable, Explosive, Oxidizer, Corrosive, etc.), pictograms, and hazard statements will be assigned to specific hazard categories and classes, and must be included on product labels. The hazard symbols, signal words, and hazard statements have been standardized. In addition to the standardized information, a product identifier, first aid statements, precautionary statements, manufacturer or supplier information, and any other pertinent supplemental information must be included on each label.
Once a chemical is brought into the workplace, the GHS required label must be maintained on the supplied container. The GHS label can also be used for workplace containers (such as storage tanks); however, it may not be specifically required. Depending on OSHA’s final ruling, employers may be allowed to use alternative written or displayed formats for transmitting hazard information to employees when such a format is more appropriate to the workplace, as long as the format communicates the information as effectively as the GHS label. For example, label information could be displayed in the work area, rather than on the individual containers.
Hazard Classification. The current performance-oriented Hazard Communication Standard outlines the expected outcome, but not the specific implementation steps for hazard communication. GHS takes a more detailed approach, specifying the detailed criteria and communication elements for each hazard class. The hazard classes include the following:
- Health Hazards – Carcinogen or Skin Irritant
- Environmental Hazards – Acute or Chronic Aquatic Toxicity
- Physical Hazards – Flammable, Explosive, or Oxidizing
Training. Educating employees on the label and MSDS changes due to the updated product classifications, pictograms, signal words, and hazard and precautionary statements will require the employer to plan ahead and be prepared. Training will be required within two years of the new Hazard Communication Standard going into effect.
Written Program. Your written Hazard Communication Program will need to be updated to reflect changes made with labeling and SDS.
Here are some websites that may provide you with additional information and guidance as you prepare to update your program:
- “A Guide to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS),” commonly referred to as the “Purple Book”: osha.gov/dsg/hazcom/ghsguideoct05.pdf
- The Globally Harmonized System for Hazard Communication background summary: osha.gov/dsg/hazcom/global.html
In summary, for metal finishing and plating plants, the greatest impact of the GHS will be understanding the new labeling and Safety Data Sheets. In many cases, storage areas and in-house containers will need to be re-labeled with this information.
It may be somewhat of a challenge in determining how to label containers and tanks when a combination of several chemicals, possibly from different suppliers, is used to make up a batch of process chemicals. Once you have a thorough understanding of the Safety Data Sheets and labeling requirements, you will then have the information you will need to revise your written HazCom and Training Programs.
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While the GHS standard will likely require training of your employees only for the aspects of your HazCom program directly impacted by the GHS standard, it would be a good time to thoroughly review your HazCom training program and update it as appropriate, especially regarding personal protection equipment.