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OSHA’s New Hazard Communication Standard

Scott Reisch

Seaton Thedinger

22 May 2012

Chemical manufacturers, importers, and distributors and employers whose employees may be exposed to chemicals, need to be aware of OSHA’s recent revisions to its Hazard Communication Standard (HCS).  Generally, the HCS requires that manufacturers and importers evaluate the hazards posed by chemicals they produce or import and then convey that information through labels and material safety data sheets (MSDS).  The HCS also mandates that employers inform their employees about chemical hazards through labeling, MSDSs, and training. 

OSHA’s new final rule substantially revises the HCS so that is conforms to international standards for classifying and labeling chemicals.  These revisions, some of which begin to take effect in 2013, will impact chemical manufacturers, importers and distributers as well as employers who use hazardous chemical substances in the workplace.  Highlighted below are a few of the key requirements under the new HCS for each regulated group.  A more detailed side-by-side comparison of the existing HCS to the new HCS is available on OSHA’s website.

Chemical Manufacturers/Importers

Under the new HCS, chemical manufacturers and importers must:

  • Follow new procedures for classifying hazards of chemicals and mixtures;
  • Prepare and provide uniform chemical labels that include standardized pictograms, signal words, hazard statements, and precautionary statements, along with other identifying information; and
  • Prepare and provide standardized Safety Data Sheets (which replace MSDSs) with a specific format required by the new HCS. 

Distributors

Distributors must ensure that chemicals they supply are accompanied by revised labels and SDSs and provide them to their customers.

Employers Subject to the HCS

Employers must update their written hazard communication programs, provide revised labels and SDSs to their workers who may be exposed to chemicals, and train such workers on the new requirements. 

Compliance Dates

Manufacturers, importers, distributors, and employers must comply with the new standards by June 1, 2015, except that:

  • Employers must train employees on the new labeling and SDS format by December 1, 2013;
  • Employers have until June 1, 2016 to update their written hazard communication programs, update labeling, and provide additional employee training for newly identified physical or health hazards; and
  • To account for shipments received close to the compliance date, distributors have until December 1, 2015 to cease shipping chemicals with old labels.

As many facilities conduct their hazard communication training annually, and manufacturers and importers may begin to use the new label and SDS format at any time, employers may wish to get a jump on the new training requirements during 2012.

Scott Reisch

Seaton Thedinger

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