OccuSafe Industrial Hygiene Consulting

OSHA’s standard for hazard communication has been in effect for many years under 1910.1200 for General Industry and 1926.59 for Construction. The purpose of the Hazard Communication Standard (HCS) isto protect workers from chemical-related injuries and illnesses. Under the standard, employers must have a written program when there are exposures to hazardous chemicals and other substances. The program must follow a number of requirements so employees receive training and notification so they can protect themselves from chemical hazards in the workplace.
The program must have the following:

• Identification: Create a complete inventory of your chemicals. Take the broadest view of what is a chemical. The HCS covers chemicals in all physical forms: liquids, solids, gases, vapors, fumes, and mists whether they are contained or not. The hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered. If it is not hazardous, it is not covered. Identify the chemicals in containers, including pipes, and chemicals that are bi-products of work operations. Make a list of all chemicals in the workplace that are potentially hazardous.
• Labeling: In-plant containers of hazardous chemicals must be labeled, tagged, or marked with the identity of the material and appropriate hazard warnings. Employers purchasing chemicals can rely on the labels provided by their suppliers. If the employer subsequently transfers the material from a labeled container to another container, the employer must label that container. The Global Harmonization System (GHS) should be used for most containers.
• Safety Data Sheets (SDS): Chemical manufacturers and importers are required to obtain or develop an SDS for each hazardous chemical they produce or import. Employers must have an SDS for each hazardous chemical used and they must be readily accessible to employees when they are in their work areas during shifts. Under the GHS, the format and information found in an SDS has been standardized. Employers should use an SDS as a basic source of information. For operations that use especially hazardous chemicals, there are no substitute for company and industry standards and procedures.
• Training: Provide training and information to each employee who may work in an area with a hazardous chemical(s) prior to initial assignment or when there is a change in the chemicals or process. Each employee should be able to identify the hazardous chemicals in the area, know the signs and symptoms of exposure, how to protect themselves from exposure, emergency procedures, and the location of the SDSs and other information about the chemicals they work with.

A final rule to update and amend the HCS was issued May 20, 2024 and it took effect on July 19, 2024. It includes:

• Specific criteria for classifying health and physical hazards.
• Updated labeling with standardized pictograms and hazard statements.
• A new 16-section format for SDS.
• A new requirement to train workers on the new SDS and labeling system.

The reason for updating the standard is so the standard better aligns with the Global Harmonization System (GHS). and improve the existing HCS. In 2003, the United Nations adopted the GHS of classification and labeling of chemicals. It includes criteria for the classification of health, physical and environmental hazards, as well as specifying what information should be included on labels of hazardous chemicals as well as safety data sheets. It includes pictograms for labeling of hazardous substances.

For those employers who have an existing Hazard Communication Program, make sure it complies with these changes. For those who have not implemented a program, first identify all hazardous substances, then comply with requirements of the standards.