26 Jun OSHA’s GHS Revisions to Worker Right-to-Know Effective Today
Source: Safety.BLR.com
May 25, 2012
OSHA’s changes to the hazard communication standard, or worker right-to-know rule, go into effect today, May 25, 2012. The revisions align U.S. worker right-to-know requirements with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals, or GHS. The changes are designed to reduce confusion about chemical hazards in the workplace, and improve safety training and worker understanding of chemical hazards in the workplace through improved chemical labeling and the new 16-section safety data sheets, or SDSs. The SDSs will replace the existing material safety data sheets.
The changes will affect over 5 million employers and 40 million workers.
OSHA will allow employers a 4-year transition period to comply with all of the new GHS requirements in the hazard communication (HazCom) rule.
4-Year GHS Compliance Transition Period
| May 25, 2012 to November 30, 2013 All employers that use, handle, store chemicals |
Train employees how to read and interpret chemical labels and (material) safety data sheets in compliance with either:
|
| December 1, 2013 All employers that use, handle, store chemicals |
Train employees about the new GHS-compliant chemical labels and SDSs. |
| June 1, 2015 Chemical manufacturers, importers, distributors |
Comply with all the requirements of the GHS rule, including classify chemical hazards and prepare new labels and SDSs. Distributors have until December 1, 2015 to comply with the shipping requirements for GHS-compliant labels. |
| December 1, 2015 All employers that use, handle, store chemicals |
All shipments of chemical containers must include the new GHS-compliant label (signal word, pictogram, hazard statement, and precautionary statement). |
| June 1, 2016 All employers that use, handle, store chemicals |
Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. |
Transition Period for Signage and Labeling of Specific Toxic Substances
| December 1, 2013 All employers that use or handle specific toxic substances |
Affix GHS-compliant labels to containers of protective clothing, equipment, and waste debris contaminated with specific toxic substances such as asbestos, chromium (VI), lead, cadmium, benzene, and listed carcinogens. |
| June 1, 2016 All employers that use or handle specific toxic substances |
All employers that use or handle specific toxic substances |
Phase-In Period for the GHS Chemical Label and SDS
Employee training. Many employers will go through a phase-in period where both old and new-style chemical labels, MSDSs, and SDSs will be present in the workplace. Until December 1, 2013, OSHA will allow employers the choice to train employees under the pre-GHS HazCom requirements, or the HazCom with GHS amendments, or both.
Start training ASAP. OSHA has also stated in the preamble to the GHS amendments that “the training needs to be completed by the time employees begin to see the new labels and SDS rather than waiting until after the transition has been completed.”
Therefore, employers should review all chemical labels, MSDSs, and new SDSs shipped to them. Once they start to receive the new GHS-compliant labels and SDSs, it would be prudent to immediately start training employees how to read and interpret them. For many employers, the GHS-compliant training should be integrated with training for the older labels and MSDSs. Once employers start to receive the new GHS-compliant labels and SDSs, it would be prudent to immediately start training employees how to read and interpret them.
SDS and MSDS file management. During the phase-in period, OSHA will not require employers to maintain two sets of MSDSs and SDSs for compliance purposes.
State Laws
By September 22, 2012, states with OSHA-approved state safety and health regulatory programs must add OSHA’s GHS amendments to their hazard communication standards. 21 states, Puerto Rico, and the U.S. Virgin Islands have OSHA-approved programs that regulate private (private businesses and nonprofit organizations) and public (state and local governments) sector workplaces. States may adopt the revisions earlier, and some states may adopt their own revisions that are stricter than federal requirements. See the relevant state Hazard Communication Standard analysis for updates.
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