by Becky Szafranski
1. March 2011
On December 20, 2010, the Fall 2010 Unified Agenda was published by the US Department of Labor for regulations of the Occupational Safety and Health Administration (OSHA). The Unified Agenda confirmed the next steps toward the adoption of final rules, which will overhaul the OSHA Hazard Communication Standard (HCS). The rulemaking process, which began in September of 2006, is expected to end with a final rule being completed in August 2011.
OSHA’s current HCS regulations require any employer with hazardous chemicals in the workplace to implement a hazard communication program, including container labeling requirement
s, material safety data sheets (MSDS) and employee training. The new rules aim to bring US requirements in line with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) which is being implemented worldwide, including adoption by the United Nations and European Union.
In a fact sheet on their website, OSHA identifies four major changes to the HCS following the implementation of the new GHS rule. First, GHS will provide additional criteria to improve hazard classification based on health and physical hazards. Second, a new labeling standard will be implemented, including required signal words, pictograms and hazard statements. Third, the new regulations will require safety data sheets in a 16-section specified format. Finally, GHS regulations do not specifically address training of employees, but the proposed HCS does include some training requirements for workers within two years of the final rule, to ensure understanding of the new labels and safety data sheets.
Expected benefits of the rule include consistency in international trade markets and increased safety for workers handling hazardous chemicals. Under current regulations in the US and internationally, companies are often required to comply with differing hazard communication requirements based on the multiple countries where their products are used or sites are located. As more countries adopt GHS regulations, companies could potentially spend less money focusing on complying with varied requirements. Increased consistency of information provided on labels, clear pictograms and standardized precautionary statements should also improve the safety of workers exposed to and working with hazardous chemicals.
OSHA characterizes costs of implementation of GHS as a “one-time transition cost” for affected industries and companies. Costs are likely to include reclassification of chemicals and training of workers on new label and safety data sheet information and modified HCS standards.
What actions does your company need to take to be ready for the implementation of new GHS requirements? Will the customer be better served using the new requirements? Do you think the benefits will outweigh the costs?
