OSHA Improves Chemical Labeling

Simply giving an employee the MSDS to read does not satisfy the training provisions of the GHS.


If you have heard a lot of buzz about OSHA recently, it is for good reason. What is happening with OSHA? OSHA has recently revised its current hazard Communication Standard, 29 CFR 1910.1200 so it will align with what is known as the GHS, Globally Harmonized System of Classification and Labeling of Chemicals.

The original Hazard Communication Standard of 1983 gave workers the right to know. The revised standard gives workers the right to understand. OSHA cites that the revisions will enhance worker comprehension, especially for low and limited literacy workers and reduce confusion in the workplace. The new standard should provide workers quicker and more efficient access to information on Safety Data Sheets resulting in safer handling of potentially dangerous chemicals.

 

Addressing common questions

Why is OSHA changing its requirement?

OSHA is simply getting on the same page as the rest of the world. In 1992 the United Nations Conference on Environment and Development came to an agreement that a globally harmonized system of recognition and placarding be developed and managed by an international group of countries to promote enhanced understanding of hazardous material exposure and handling. The UN adopted the Global Harmonization System (GHS), modeled after the U.S., Canadian, and European systems in 2003 with a goal of each country adopting and implementing by 2008. Not only does the new system protect humans and the environment, it also will serve to heighten global trade by reducing barriers to communication that formerly existed. GHS will create a system in countries where systems did not exist.

What part of the standard is affected by GHS?

The classification criteria for health and environmental standards as well as physical standards are now in sync with GHS. Communication requirements for labeling, Safety Data Sheets, and training fall within the scope of the new requirements. With the exception of aquatic toxicity, the DOT is already harmonized with the international transport system.

Who is affected and what is the dateline?

The second Advance Notice of Public Rulemaking was published in 2009, followed by a final ruling. Employers are now required to train employees by Dec. 1, 2013.

Who needs this revised GHS training?

Employees in virtually all industries and occupations, especially pilots, mechanics, and line service personnel in general aviation, who are continually exposed to jet fuel, oils, lubes, will benefit from training. OSHA-compliant Hazmat GHS training is essential for any worker who has any exposure to hazardous chemicals. OSHA has mandated that all affected workers must be trained to read and understand the new safety data sheets and chemical labeling criteria.

What specifically should training address?

Compliant training courses should familiarize workers with knowledge of the new safety data sheet (SDS) format and the new chemical labeling criteria of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), as well as highlight OSHA-mandated guidelines, OSHA 1910.1200 regulations.

How often does an employer have to train its employees?

A new hazmat employee who changes job functions may perform those functions prior to completion of this training provided the employee performs those functions under direct supervision of a properly trained and knowledgeable hazmat employee; and the training is completed within 90 days after employment or job function change.

Employees must receive the required training every three years, or any time there is a change in job function. A change in the Hazardous Materials Regulations constitutes a change in job function.

Who is considered a hazmat employer?

A hazmat employer means a person who employs or uses at least one hazmat employee on a full-time, part-time, or temporary basis; or is self-employed (including an owner-operator of a motor vehicle, vessel, or aircraft) transporting hazardous material in commerce; and who:

  • Transports hazardous material in commerce;

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