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Specialty Graphic Imaging Association

OSHA HazCom Standard

All companies are subject to the OSHA Hazard Communication Standard.

Effective May 2012, the Hazard communication Standard (HCS 2012) was revised to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and SGIA is here to help you (and your employees) comply with the new requirements.

A newly developed Right to Know Training (RTK) program is available, with the idea of keeping your workplace safe in mind. The updated program is foremost made up of a DVD that incorporates information regarding new hazard warning labels and safety data sheets. This instructional video also covers personal protective equipment in the workplace.

Ouick Look at the Upcoming Deadlines:

While there were several changes brought about by the revision the three most significant changes included:

  1. Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards, as well as classification of chemical mixtures.
  2. Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
  3. Safety Data Sheets: The new format requires 16 specific sections in a specific sequence in order to ensure consistency in presentation of communication of hazard information.

In addition, OSHA outlined requirements for employers to implement new training programs that would assist employees to understand the new GHS elements adopted under HCS 2012.

Employee training:

To facilitate understanding, OSHA requires that employees be trained on all elements of the Hazard Communication Standard initially when hired and before they are exposed to any hazardous chemicals at the worksite.

OSHA also required existing employees to be trained on the new label and SDS formats by December 1, 2013 or if hired after December 1, 2013, immediately prior to being exposed to hazardous chemicals at the worksite.

Transition period and compliance deadlines:

As part of the adoption of GHS with the HCS and as a result of the significant changes, a transition period was established by OSHA so that chemical manufacturers, chemical distributors, and employers have time to prepare updated Safety Data Sheets, updated container labeling, relevant program materials and employee training that will comply with the HCS 2012.

The effective dates for the transition period are as follows:

  • By December 1, 2013 -- Employer must train employees on recognition of the new Safety Data Sheet and Warning Label formats
  • By June 1, 2015 -- Chemical manufacturers must comply with all modified provisions of the HCS 2012, including updated Safety Data Sheets and shipped container labeling. (See accompanying factsheet on the enforcement discretion allowances)
  • By December 1, 2015 –Distributors must begin using the GHS label format for shipped containers. (See accompanying factsheet on the enforcement discretion allowances)
  • By June 1, 2016 -- Employers need to update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

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