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Top 10 FAQs about OSHA’s new GHS training requirement

OSHA required more than five million U.S. businesses must train about 43 million employees on the new label elements and safety data sheets (SDSs) included in OSHA’s hazcom standard revisions by Dec. 1, 2013.

OSHA’s Hazard Communication Standard is being revised to comply with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

It’s the most significant OSHA standard update in years, and your peers have been asking lots of questions. So, here are the top-10 most frequently asked questions about GHS.

  1. What’s the biggest change? The requirements for hazard communication training are mostly the same. It’s the details that are different. OSHA has added and updated definitions of the various classifications of hazardous chemicals. Workers should learn the new signal words on labels and SDSs, and the new standardized pictograms.
  2. What are the deadlines? By Dec. 1, 2013, companies have to train employees about the new features on labels and SDSs. Up until June 1, 2016, manufacturers and distributors can use old or new style labels and SDSs. After that, they must all be under the new system.
  3. What are the new labeling requirements? There are two types of containers. Shipped container labels must have six sections on the labels: identifier, supplier, pictograms, signal words, hazard statements and precautionary information. If employers repackage chemicals into smaller containers for employee use, labels for these containers don’t have to be like the shipped containers. Workplace container labels must have enough information on the container to help the employee find the appropriate SDS.
  4. How are SDSs changing? SDSs will now be a standard 16-part form, although sections 12 through 15 aren’t mandatory because they’re outside of OSHA’s jurisdiction. While workers should know what each section is about, Section 2, which lists all substance hazards, should probably get the most attention. The material in Section 2 is good basic information to include on workplace container labels.
  5. What are the employee training requirements? Employees must learn about the new label elements and the new SDS format, including what’s in each section.
  6. What’s the biggest change for companies that must produce new SDSs for products they manufacture? The biggest change will be the reclassifying of all chemicals.
  7. What should we do with the old versions of SDSs, and how long should we keep them? Companies need to keep SDSs for all substances they are using. (Employee medical records are a different story, however. They must be kept much longer, even after the company is no longer using the chemical.) Right now, you’re likely seeing a hodgepodge of labels. Some look like the old style, some like the new and some are even in between. Employers are not responsible for updating older shipped container labels. They are responsible for updating workplace containers if new hazards are identified.
  8. Does electronic management of SDSs change? The basic requirements stay the same. Of course, companies will have to update the new SDSs in their electronic management programs as they receive them. There must be no barrier to access for employees to these electronic records. Even if they use an electronic storage system, employers must be able to produce SDSs for all chemicals they’re using in a reasonable amount of time if asked by OSHA. Bonus question: What’s a reasonable amount of time? Generally, OSHA inspectors expect employers to be able to produce SDSs within 20 minutes.
  9. Are other OSHA standards affected by the changes in the hazcom standard? Yes, there are implications for some standards, such as ones which address specific hazardous materials. Example: OSHA’s lead standard.
  10. What is Canada doing about adopting GHS? Canada has set a June 1, 2015 deadline for adopting GHS. It plans to pre-publish its plans in Spring 2014. So far it appears there will be a lot of similarities to the U.S. version. That is one of the benefits of GHS: Labels and SDSs will be more standardized after adoption across the world.

(Based on a presentation by Glenn Trout, President, and Chuck Haling, VP Sales, MSDSonline, at the National Safety Council’s 2013 Congress & Expo in Chicago)

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Comments

  1. Charlie Hunt says:

    Training is an integral part of any hazard communication program. Under
    the OSHA Hazard Communication Standard (29 CFR 1910.1200), all employers
    are required to inform and train their employees at the time of their
    initial assignment to a work area where hazardous chemicals are present,
    and wherever a new hazard is introduced into the work area.

    See more at http://ablesafety.com/hazardcommunications/

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