Compliance Headline News
Hazard Communication 2012 - and the Globally Harmonized System
What? The title of this information piece can confuse even the most erudite engineer and safety professional but, due to the need for the promotion of international commerce and the perceived need to consolidate the language of warning on container labels for workers the above program is being implemented by OSHA over the next 4 years.
By December 1, 2013 all employees in the United States will be required to learn the new symbols that are initiated in the HCS 2012 and the GHS because a need was found to consolidate a new easily and harmonized definition of hazards. Specific criteria have been established for labels and a harmonized format for what was the Material Safety Data Sheet (MSDS) will become the Safety Data Sheet. Sounds kind of the same but it will be different because the labels will no longer carry the Red-Blue-Yellow and White sections with numbers from 0 to 4 to indicate a hazard. The hazard will now be one of the 9 symbols in the chart below and the SDS will have a 16 section format.
The HCS Pictograms and Hazards are similar but not the same as those used on commercial trucks in the US now except that the colors are different. The specific hazard will show a Pictogram to describe the conditions shown in the RED diamond shape with a white background. They have changed the way hazards are defined in what were "performance-oriented" identification of hazards to a "specification" approach. They will now be Hazard Classified based on what they are rather than what they do.
The new Hazard Communication Standard carries responsibilities for manufacturers of chemicals and Shippers, Importers and Distributors as well as the customer or business that will ultimately use the chemicals in the workflow process. Just like you receive a MSDS now you will receive a SDS with your chemical shipment, this will be in place by June 1, 2016. You will be required to ultimately replace the MSDS with the SDS in your file in the future and during the transition files must be kept in an integrated fashion so as not to confuse those with the need to study the SDS.
Your current written Hazard Communication program will need to be updated and in some cases replaced unless you have been updating the information in the training part of your HazCom program since you first put it in place. It might be time to reevaluate the written program materials that you have been using to train your employees. This goes beyond the OSHA poster that you have posted on the wall (it is not a HazCom training program, it is a poster). OSHA still requires you to have a written Hazard Communication Program in place that has a training component so you can teach the employee what is required by OSHA. I have to say here that IF you have an ongoing relationship with a consultant or training provider you will most likely be upgraded with new program materials and training materials.
