From Right-to-Know to Right-to-Understand

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OSHA’s Hazard Communication Standard (HCS) has been revised. If you haven’t already seen changes to Material Safety Data Sheets (MSDS) and labels on chemical products, you will soon. OSHA is requiring that employers train employees on the changes by December 1, 2013.

A little background: in 1983 OSHA established the HCS. The HCS requires employers to ensure that employees know about the chemical products used or stored in their workplace and the hazards associated with those chemicals so that employees can use and handle the chemicals safely. Also referred to as the Right-To-Know Law, the HCS requires that information be provided to all employees who have the potential of being exposed to a hazardous chemical through normal use or in an emergency situation. Required information includes: a hazardous chemical inventory; MSDS for each chemical on the inventory; labels, tags, or signs on primary and secondary containers holding chemicals; and a written hazard communication program. The HCS did not specify a common or coherent approach to classifying chemicals and communicating the information to employees.

To improve safety and health of workers through more effective communications on chemical hazards, OSHA recently revised the HCS to adopt the Globally Harmonized System (GHS). The GHS, also known as the Right-to-Understand System, is an international approach for providing easily understandable information to employees. The adoption of the GHS includes three major changes to the HCS:

• Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures.
• Labels: Chemical manufacturers and importers will be required to provide a label that includes a common worldwide signal word, pictogram, and hazard statement for each hazard class and category.
• Material Safety Data Sheets: The nine-section MSDS will now be called a Safety Data Sheet (SDS) and will have a specified sixteen-section format.

Many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDS. That’s why many workplaces have already begun to receive labels and SDSs that are consistent with the GHS. It is important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they are familiar with them, understand how to use them, and access the information effectively.