This article was originally posted on Safety.BLR.com.
On July 20, OSHA announced the release of new instructions for its inspectors to ensure the consistent enforcement of its revised Hazard Communication Standard (HCS). So what will inspectors be looking for in your HazCom program if your facility is inspected? Keep reading to find out.
OSHA revised the Hazard Communication Standard in March 2012 to align with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The intention of the revisions was to improve the quality, consistency, and clarity of chemical hazard information that workers receive.
Among the revisions, chemicals must now be classified according to specified hazard criteria, chemical container labels must contain hazard pictograms and other key information, and safety data sheets (SDSs), formerly material safety data sheets (MSDSs), must be written in a specified 16-section format.
The instruction outlines the revisions to the HazCom standard, such as the revised classification of chemicals, label elements for containers of hazardous chemicals, and the required format and content for safety data sheets. It also explains how the revised HazCom standard is to be enforced during its phase-in period and after the standard is fully implemented on June 1, 2016.
The revised Hazard Communication Standard required employers to train workers on the new label elements and safety data sheets by December 1, 2013. Chemical manufacturers, importers, and distributors had to comply with revised safety data sheet requirements by June 1, 2015.
Manufacturers and importers had to comply with new labeling provisions as of June 1, 2015. Distributors have until December 1, 2015 to comply with labeling provisions as long as they are not relabeling materials or creating safety data sheets, in which case they must comply with the June 1 deadline.
In the directive, OSHA states that the agency will typically not cite chemical manufacturers, importers, and distributors that lack a GHS-compliant SDS or label if these companies can show that they “have exercised ‘reasonable diligence’ and ‘good faith’ to obtain HCS 2012-compliant SDSs from upstream suppliers but have not received them.”
During the transition period, when OSHA determines that a violation exists either under HCS 1994 or HCS 2012, citations to manufacturers or importers will be issued for both versions of the standard.
The instruction is available here.