HazCom 2012: OSHA's Revised Hazard Communication Standard
February 27, 2013
In March of last year, the Occupational Safety and Health Administration (OSHA) published a final rule (HazCom 2012) aligning its Hazard Communication Standard (HCS) with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
By way of background, OSHA’s HCS requires chemical manufacturers and distributors to assess the hazards of chemicals they produce or import and to subsequently provide product labels and safety data sheets conveying that information to downstream users of the chemicals, such as employers. The HCS also requires employers to make these labels and safety data sheets available to its employees at the workplace.
The inconsistencies between the HCS and the GHS required manufacturers to produce different labels and safety data sheets for the same product when it was marketed in different countries. OSHA’s modifications to the HCS in HazCom 2012 were intended to reduce these inconsistencies. Major changes under HazCom 2012 include: (1) revised criteria for classifying chemical hazards; (2) revised labeling requirements; and (3) a new 16-section format for safety data sheets.
Recognizing the practical difficulties in adapting to these significant changes, HazCom2012 allows a lengthy phase-in compliance period for manufacturers, distributors, and employers. Manufacturers and distributors must be in full compliance by June 1, 2015, except that they may ship materials with old HCS labels until December 1, 2015. Meanwhile, employers have until June 1, 2016 to update all labels and safety data sheets in the workplace. However, employers must provide training to their employees on the updated labels and data sheets by December 1, 2013.
Although conducting training is the only formal requirement for employers until 2016, it is advised that employers take the following steps now to ensure a smooth transition:
- Make note of materials stored in your workplace with outdated labels and safety data sheets, and attempt to deplete and turn over these materials in a practical yet timely manner.
- Instruct employees (especially those involved in purchasing) to be on the lookout for updated safety data sheets.
- Request updated data sheets from manufacturers and distributors or information regarding their plans/timetable for updating their materials.
For more information on HazCom 2012, OSHA has provided a detailed information page addressing the new regulations, available here.
