SHA’s highly anticipated changes for chemical labeling are now available for public viewing. As expected, the new changes incorporate several key elements of the United Nation’s Globally Harmonized System of Chemical Labeling (GHS) into the agency’s own Hazard Communication Standards (HCS). However, new changes for labeling won’t require implementation for several years.
OSHA’s new labeling requirements are expected to have the greatest impact on U.S.-based chemical manufacturers and chemical importers, with few mandatory changes slated for other general chemical storage. Chemical manufacturers and importers are targeted by the new standards to ensure their chemical containers will display a label similar to those now used in Europe and many other GHS adopters beginning June 1, 2015.
The GHS-inspired standards will require chemical manufacturers and importers to label chemical containers with a 1) harmonized signal word, 2) GHS pictogram(s), 3) a hazard statement for each hazard class and category and 4) a precautionary statement.
The following describes these elements in greater detail:
- Harmonized signal word: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for less severe hazards.
- GHS pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e., a red diamond).
- Hazard statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
- Precautionary statement: a phrase that describes recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous chemical; or improper storage or handling of a hazardous chemical.
Employers who only store chemicals have the flexibility to use OSHA’s new labeling system or stick with the old NFPA 704 Hazard Rating System or Hazardous Material Information System (HMIS) if they choose. However, the information supplied on these labels must be consistent with the newly revised HCS, e.g., no conflicting hazard warnings or pictograms.
Keep in mind, OSHA plans to update the old, “alternative” labeling system requirements June 1, 2016. Since alternative labeling requirements may change in fewer than four years, and employers must train employees to understand new label elements and the new SDS format by December 13, 2013, voluntarily switching to the revised HCS labeling now will likely reduce costs over the long run and reduce confusion in the workplace.
The newly revised HCS outlines eight specific GHS pictograms for use on labels. Each is surrounded by a red border and designed to convey the health and physical hazards of chemicals. A ninth, environmental, pictogram may be required by other agencies, but not by OSHA. Environmental hazards are not within OSHA’s jurisdiction.
In addition to the new labeling requirements, chemical manufacturers must now supply customers with a GHS-standardized, 16-section SDS. The new format provides customers implementing the new HCS standards an easy-to-understand reference for labeling.
OSHA officials say the new changes provide “… a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets.” Once implemented, OSHA leaders believe the revised standard will improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals. This latest update, they say, will also help reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store and use hazardous chemicals. Cost savings are also anticipated for American businesses that periodically update safety data sheets and labels for chemicals covered under the hazard communication standard.
OSHA estimates over 5 million workplaces in the United States will be affected by the revised HCS. These are all workplaces where employees — a total of approximately 43 million — could be exposed to hazardous chemicals. Among the 5 million workplaces, there are an estimated 90,000 establishments that create hazardous chemicals. Combined, these chemical producers employ nearly 3 million workers. OSHA expects to make updates to its own HCS every two years in order to keep up with the U.N.’s anticipated changes.