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New chemical rules will ease complexity

Scott Alquist

With the expanding global marketplace, chemicals produced, transported and used throughout the world can present a serious danger to people and our environment. And without a recognized globally harmonized approach to identification and communication of hazards, we are all at risk. That’s why the OSHA standard on hazard communication (also known as the employee right-to-know) requirements are about to change.

Beginning this month, OSHA says employers must begin to update their hazard communication programs and labeling systems in phases over the next two to three years to come in line with the new Global Harmonization System (GHS). This is meant to take some of the confusion out of the way chemical hazards are identified and how it is communicated to your affected employees. This new requirement sets the standards for labeling, employee training and creates a standardized hazard classification system.

One of the biggest changes will be a conversion from material safety data sheets (MSDS) to safety data sheets (SDS). As everyone knows, there never was a mandatory format for MSDS. And without a consistent format, information can be confusing or even misinterpreted. Well, as I said, that is all about to change.

Let’s address the new hazard classification system, which is broken down into three specific or major hazard groups: physical, health and environmental hazards. Within each of these areas, there are classes meant to more accurately describe the hazards. In the health hazard group, there are 10 classes ranging from acute toxicity to aspiration hazards. In the physical hazards group, this new system expands the current nine hazards classifications to 16. And the environmental hazards group describes the hazards as either hazardous to the aquatic environment or hazardous to the ozone layer. Some groups will have categories defined as either Category One or Category Two based on the degree of danger or hazard presented by that material or chemical.

The next change deals with how labeling systems are used. Currently most affected companies use the Hazardous Materials Identification System (HMIS label). This identifies the basic hazards associated with the contents of the container: the name of the chemical, along with flammability, health and reactivity concerns. The last three sections are further identified by color-coding: flammability, red; health, blue; and reactivity, yellow. Many also have a white section at the bottom that identifies the personal protective equipment necessary under normal use conditions. Within the red, blue and yellow sections, a numeric system identifies the level of hazard from zero to four, with four being the most dangerous. This new system also requires the use of signal words, DANGER or WARNING, and implements symbols or pictograms to explain the hazard. Additionally, other changes will be made, such as allowing supplementary information that meets specific guidelines. This allows a competent authority to provide more detail without adding clutter, contradictory information or content about hazards not yet incorporated into the GHS. Don’t take this to mean that the HMIS labels or other recognized means of giving workers the same information can no longer be used, but the GHS does state that the new labels are required on containers supplied to the workplace. One alternative they reference is that the information that is on the label can be displayed in the work area rather than on individual containers. Should new information on a specific chemical or material that changes the classification become available, the labels must be updated to reflect that change.

The third requirement change is the implementation of the new Safety Data Sheet (SDS) format, which now mandates 16 sections in a pre-designated format and sequencing. In my opinion, this is likely to be the best change to come to fruition. I can remember times when I compared five MSDSs for the exact same chemical from five different suppliers and the information did not match! This new classification system should make this a problem of the past. It won’t matter if a chemical or material comes from Alabama or Zimbabwe as the information should be more complete and accurate. This is especially crucial to employers, as this is one of the primary tools used when conducting training and meeting the numerous mandates set forth by other agencies, such as the USEPA and USDOT.

The fourth and final topic is employee information and training. According to my research and OSHA information, the current hazard communication training requirements are much more detailed than those referred to under GHS. The OSHA hazard communication training requirements go into detail and address topics such as operations within the work area where hazardous chemicals or materials are present; location and availability of the written hazard communication program; how to detect the presence of a haz-mat; and how to interpret a MSDS and the label system used in the workplace. GHS simply states that if the employee needs to interpret information that is on a label or contained in a SDS, then the training should be commensurate with the nature of the work or exposure. Vague at best! I feel this section of the GHS is a potential failure point. While OSHA standards addressing training are quite comprehensive and possibly time-consuming you are accomplishing your mission by protecting your workers. Remember the old saying, “Knowledge is power,” in this case it is the power to work safely.

GHS has been a long time in the making, with direction provided by many countries, agencies and companies. This new system has the potential to increase everyone’s efforts in protecting our companies, our employees and the environment from the hazards of the chemicals and materials we encounter each day.

For further details, a comparison of the current OSHA standards and the new GHS requirements visit http://www.osha.gov/dsg/hazcom/ghoshacomparison.html#4.

Scott Alquist is manager of the Truckee Meadows Community College Safety Center. Contact him at salquist@tmcc.edu or 857-4958.