Editorial · December 6, 2013
OSHA Hazard Communication: Labels and Training Basics
OSHA hazard communication rules are moving to standard label elements and a 16-section safety data sheet. The first deadline has passed. By December 1, 2013, employers had to train workers on the new label elements and the new sheet format.
What the rule does
OSHA, the Occupational Safety and Health Administration, revised its Hazard Communication Standard. The Federal Register published the revision on March 26, 2012. The revision brings the standard in line with the United Nations' Globally Harmonized System of Classification and Labelling of Chemicals, known as the GHS. The final rule took effect on May 25, 2012.
The old standard let chemical makers and importers pick their own formats for labels and sheets. OSHA's questions and answers name three big changes. The rule gives specific criteria for classifying health and physical hazards, and mixtures. It also sets what must appear on labels. And safety data sheets (SDSs), which convey hazard information to customers, will follow a specified 16-section format.
OSHA says chemical makers and importers must evaluate the hazards of the chemicals they produce or import, and prepare labels and SDSs. All employers with hazardous chemicals in their workplaces must have labels and SDSs for their exposed workers. They must also train those workers to handle the chemicals appropriately.
What the new labels show
Under the revised standard, chemical makers, importers and distributors must ensure each container of hazardous chemicals that leaves their workplace is labeled. By June 1, 18 months after the training deadline, the label must have six items. Distributors get six more months for containers labeled by the maker or importer. The items are:
- A product identifier, such as the chemical name, code number or batch number
- A signal word
- Hazard statements, which describe the nature of the hazard
- Precautionary statements, which describe recommended measures to minimize or prevent harm from exposure to the chemical or from improper storage or handling
- Pictograms
- The name, address and phone number of the maker, importer or other responsible party
Only two signal words are used. Within a specific hazard class, "Danger" marks the more severe hazards and "Warning" the less severe. A label carries one signal word, and if a chemical's hazards call for both, only "Danger" should appear.
On shipped containers, a pictogram is a black symbol on a white background inside a red frame set on a point, like a diamond. A red frame with no symbol is not allowed on the label. The GHS has nine pictograms, and OSHA requires eight. The environmental one is not required because environmental hazards are outside OSHA's authority.
Employers can also make their own workplace labels. These can give the product identifier plus words, pictures or symbols that, with other information workers can reach right away, describe the specific hazards. If a label is removed or defaced, the employer must relabel the container.
The 16-section safety data sheet
The old "material safety data sheet," or MSDS, is now a "safety data sheet." OSHA says the information is largely the same, but the revised standard requires a consistent 16-section format, in this order:
- Identification
- Hazard(s) identification
- Composition/information on ingredients
- First-aid measures
- Fire-fighting measures
- Accidental release measures
- Handling and storage
- Exposure controls/personal protection
- Physical and chemical properties
- Stability and reactivity
- Toxicological information
- Ecological information
- Disposal considerations
- Transport information
- Regulatory information
- Other information, including date of preparation or last revision
The product identifier on the label must also appear in Section 1. OSHA says Section 8 will always contain information about exposure limits, engineering controls (for example, local exhaust ventilation) and ways to protect yourself, including personal protective equipment. Sections 12 to 15 must have headings, but OSHA will not enforce their content because those matters are handled by other agencies.
The deadlines, in order
OSHA set four dates. The later three fall 18, 24 and 30 months after December 1, 2013. During the transition to these dates, chemical makers, importers, distributors and employers may follow the old standard, the new one, or both.
- December 1, 2013: employers must train workers on the new label elements and SDS format.
- June 1, 18 months later: makers, importers, distributors and employers must comply with all the changed parts of the rule, including the rules for preparing the new labels and SDSs. Two exceptions follow.
- December 1, 24 months later: after this date, distributors may not ship containers labeled by the maker or importer unless the label meets the new rules.
- June 1, 30 months later: employers must update alternative workplace labeling and their hazard communication program as necessary. They must also give any added training on newly identified physical or health hazards.
OSHA says it is acceptable for labels and SDSs in both formats to be in the same workplace while the changes phase in. Employers do not have to keep two sets of labels and SDSs for compliance purposes.
What a shop or plant can do now
- Check your training against OSHA's minimum list. For labels, it covers the six label items, how workers might use labels on the job, and how the parts work together. For SDSs, it covers the 16-section format, including the type of information in the various sections, and how the label relates to the sheet.
- Teach in a way workers understand. OSHA requires training in a manner and language employees can understand. If employees are not literate, telling them to read training materials will not satisfy the employer's training obligation.
- Keep the sheets within reach. Employers must keep a copy of the SDS for each hazardous chemical in the workplace. It must be readily accessible during each work shift to employees when they are in their work areas. A binder or computer works if employees get immediate access without leaving the work area when needed, and a back-up is available in a power outage or other emergency.
- Name someone to chase missing sheets. OSHA says employers may want to designate a person to obtain and maintain the SDSs. If one is missing, they should contact the manufacturer.
- Talk to suppliers. OSHA encourages employers to work with their suppliers to get the information they need by the dates they need it.