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Hazard Communication
The HSC (29 CFR 1919.1200) requires chemical manufacturers and importers to assess the hazards of chemicals which they produce or import and provide that information to employers. Employers must then provide information to their employees about the hazardous chemicals to which they are exposed by means of a hazard communication program, labels, safety data sheets, and training. The HCS also requires distributors to transmit this information to employers. Other countries have hazard communication rules which are different from the HCS with regard to the scope of chemicals covered, the definition of hazards, the specificity of requirements and the use of symbols and pictograms. The inconsistencies between the various laws are substantial enough to require different labels and safety data sheets to be developed for the same product when it is marketed in different countries.
The Proposed Changes
OSHA has made a preliminary determination that the proposed changes to the HCS will improve the quality and consistency of information provided to employers and employees regarding chemical hazards and protective measures. OSHA anticipates that improved information will reduce the incidence of chemical-related occupational illnesses and injuries. OHSA asserts that the adoption of the new standard will have the added benefit of standardizing hazard communication rules among various countries. The proposed changes to the HCS include: revised criteria for classification of chemical hazards; revised labeling provisions that include requirements for use of standardized signal words, pictograms, hazard statements, and precautionary statements; a specified format for safety data sheets; revisions to the definitions of terms; and requirements for employee training on labels and safety data sheets.
Compliance
The proposed modifications to the HCS will require manufacturers and importers of hazardous chemicals to re-evaluate chemicals according to the new criteria, change labels and produce new safety data sheets within three years of publication of the final rule. Employers will be required to integrate the new approach into their hazard communication programs and conduct new training for employees within two years of publication of the final rule.
Contact Information
If you have questions, please contact:
Virginia C. Robbins at 315-218-8182; vrobbins@bsk.com
Brody D. Smith at 315-218-8225; bsmith@bsk.com
Robert H. Feller at 518-533-3222; rfeller@bsk.com
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