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Understanding OSHA’s GHS-Based Chemical Labeling: A Closer Look at Compliance and Impact

Deconstructing the Revised Hazard Communication Standard’s Chemical Label Requirements and Its Implications for the US Workforce

Key Takeaways:

  1. OSHA’s revised Hazard Communication Standard, aligned with the Globally Harmonized System (GHS) of chemical labeling, is expected to influence over 5 million US workplaces, predominantly impacting chemical manufacturers and importers.
  2. GHS-inspired standards necessitate that chemical containers bear labels featuring a harmonized signal word, GHS pictogram(s), a hazard statement, and a precautionary statement.
  3. While employers who only store chemicals have the option to use the new labeling system or continue with the old system, transitioning to the revised HCS labeling could potentially reduce long-term costs and workplace confusion.
  4. Apart from labeling requirements, chemical manufacturers must now supply a GHS-standardized, 16-section Safety Data Sheet (SDS) to customers.
  5. OSHA expects that the revised standard will enhance hazard information’s quality and consistency in the workplace, facilitate international trade, and result in cost and productivity gains for businesses.

Impact of OSHA’s Updated HCS: A Comprehensive Shift in Chemical Labeling

The updated Hazard Communication Standard (HCS) by OSHA, now aligned with the Globally Harmonized System (GHS) of chemical labeling, is set to bring significant changes to workplaces across the United States. With an estimated 5 million workplaces – inclusive of 90,000 establishments producing hazardous chemicals – due to be affected, the shift to the new chemical label requirements stands to revolutionize industry practices.

Decoding the New Label Requirements: Breaking Down the GHS Elements

The greatest impact of the updated HCS will be felt by U.S.-based chemical manufacturers and importers. Under the new GHS-inspired standards, these stakeholders will be required to label chemical containers with four key elements:

  1. A Harmonized Signal Word: This term is used to denote the severity level of a hazard and to alert the label reader to potential risks. The two signal words in use are “danger” for more severe hazards, and “warning” for less severe hazards.
  2. GHS Pictogram(s): These are graphical elements, including a symbol, border, background pattern, or color intended to convey specific information about a chemical’s hazards. Each pictogram features a distinct symbol on a white background, encased within a red square frame.
  3. Hazard Statement: Assigned to a hazard class and category, the hazard statement describes the nature of a chemical’s hazards, including, where appropriate, the degree of hazard.
  4. Precautionary Statement: This phrase offers recommended measures to minimize or prevent adverse effects resulting from improper storage, handling, or exposure to a hazardous chemical.

Flexibility for Employers and the Incentive to Shift

While these chemical label requirements are largely geared towards chemical manufacturers and importers, employers who only store chemicals are not left out. They have the option to either adopt OSHA’s new labeling system or to stick with the old NFPA 704 Hazard Rating System or Hazardous Material Information System (HMIS). However, the information provided on these labels must be consistent with the revised HCS to avoid conflicting hazard warnings or pictograms.

Even though alternative labeling systems will still be permitted until June 1, 2016, businesses stand to benefit from early adoption of the revised HCS. By training employees on the new label elements and Safety Data Sheet (SDS) format ahead of the deadline, employers can potentially reduce long-term costs and minimize confusion in the workplace.

The Reinforced Role of Safety Data Sheets

Beyond the adoption of new labeling standards, chemical manufacturers are now required to supply a GHS-standardized, 16-section SDS to their customers. This new format offers an easy-to-understand reference for labeling, simplifying the process of implementing the new HCS standards.

Anticipated Benefits: OSHA’s Vision for the Future

According to OSHA officials, the revised HCS aims to provide “a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets”. The updates are expected to improve the quality and consistency of hazard information in the workplace, facilitating safer handling and usage of hazardous chemicals.

Furthermore, the changes are believed to reduce trade barriers, streamline productivity, and bring cost savings for American businesses that regularly handle, store, and use hazardous chemicals. This strategy underscores OSHA’s commitment to continuously improve safety standards, while also considering the practical needs and efficiencies of businesses.

Understanding these new chemical label requirements is paramount for companies, as it can help them navigate through this transitional period effectively and leverage the intended benefits of the revised standards.

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