A Full Service Engineering Company MSES consultants, 609 West Main Street Clarksburg, WV 26301 (304) 624-9700 J a n u a r y 2 0 1 4 S T E P S M e e t i n g C h a n g e s T o O S H A H a z a r d C o m m u n i c a t i o n S t a n d a r d
Introduction OSHA 1910.1200 (Hazard Communication) Ensure all hazards of all chemicals are classified and that this information is transmitted to employers and employees Revised on May 25, 2012 to align with the UN s 3 rd Revision of the Global Harmonized System of Classification and Labeling of Chemicals (GHS) Also known as HazCom or HCS Previous version called HazCom 1994 New Revision called HazCom 2012 Classified: identify potential hazards of the chemical
HazCom Requirements Written Program (No Changes) Develop a hazardous chemical inventory list How site will manage labeling, safety data sheets, and training How site will communicate hazards of nonroutine tasks and chemicals in unlabeled pipes Cleaning of tanks/vessels Methods used to communicate program to other companies onsite. Multiemployer Sites drillers, service companies, consultants No Changes: no major changes to this section of HazCom 1994
HazCom Requirements Labels and other Forms of Warning Changes to this section to align with GHS Shipped containers must contain: Product Identifier Signal Word Hazard Statement Hazard Pictograms Precautionary Statements Supplier Identifier (name, address, phone #, etc.) Must train employees by deadline Shipped containers: the requirements for shipped containers and workplace containers are differ
HazCom 2012 Labels 1 Product Identifier The name of the chemical/substan ce Should match the identifier on the safety data sheet
HazCom 2012 Labels 2 Hazard Pictograms Black hazard symbol with red diamond boarder and white background OSHA adopted 8 of the 9 GHS pictograms Quickly conveys hazards to employee
HazCom 2012 Labels 3 Signal Word One of these two signal words must appear on the label DANGER for more severe hazard categories WARNING for less serious hazards Appendix C of 1910.1200
HazCom 2012 Labels 4 Hazard Statements Describes the nature and degree of hazards for a chemical Harmonized so all chemicals with the same hazard will read the same Statement
HazCom 2012 Labels 5 Precautionary Statement Measures to take to be protected from the hazards
HazCom 2012 Labels 6 Supplier Identifier The name, address, and phone number of the supplier
HazCom Requirements Safety Data Sheets (SDS) No longer MSDS s Required 16 section format Must make available to employees and have an SDS for each chemical Must update current MSDS to new SDS format s by regulatory deadlines
HazCom Requirements Training Requirements (Minimal Changes) Must provided initial training and new chemical training and must cover Locations where chemicals are used Location of written program, hazardous chemical list, and SDS s Methods used to detect chemical exposure/releases Methods used to protect employees Details of the site specific hazcom program Training Changes: only real change involves what must be covered during the phase in periods of Dec. 1, 2013 and June 1, 2016
HazCom 2012 Effective Completion Date Deadlines Requirement(s) Responsible Party December 1, 2013 June 1, 2015 December 1, 2015 June 1, 2016 Train employees on the new label elements and SDS format Manufactures must begin shipping Haz Com 2012 compliant SDS and labels based on their chemical classification The distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified hazards [and affected vertical standard specific signage] Employers Chemical manufacturers, importers, distributors, and employers Distributor Employer