OSHA’s New Final Rule For Hazard Communications In The Workplace

The Occupational Health and Safety Administration (OSHA) have after much review and commentary by various parties published their new Final Rule for Hazard Communications in the workplace. The new rules and regulations are designed to reduce the number of workplace injuries caused by miscommunication of the nature and extent of hazards.

Consistent System of Chemical Labeling

The OSHA guidelines will incorporate the international Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. Employers who import or export chemicals, or who sell or buy chemicals solely in the United States, will have a consistent system of chemical labeling and safety data sheets communicating the hazards of the chemicals. OSHA believes the revised hazard communications, which includes various hazards beyond chemicals, will provide a consistent approach to hazards, making it safer for employees.

Four Major Changes to Hazard Communication Standard

The four major changes to the Hazard Communication Standard as outlined on the OSHA website, https://www.osha.gov/dsg/hazcom/index.html, are:

• Hazard Classification: Provides specific criteria for the 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 harmonized signal word, pictogram, and hazard statement for each hazard class and category; precautionary statements must be provided.

• Safety Data Sheets: Will now have a specified 16-section format.

• Information and training: Employers are required to train workers by December 1, 2013 on the new labels elements and safety data sheets format to facilitate recognition and understanding.

Nine Pictograms Adopted By OSHA

There are nine pictograms that OSHA is adopting from GHS. Each pictogram is outlined in a red square standing on a point (baseball diamond shape). The center of each pictogram is different to delineate what the hazard is. The pictograms are:

• Health Hazard: A red diamond with the shoulder/head/chest silhouette with a large asterisk like shape in the chest. This is to warn employees the product can have the properties of, or cause, a carcinogen, mutagenicity, reproductive toxicity, respiratory sensitizer, target organ toxicity, or aspiration toxicity.

• Flame: A red diamond with a flame. This is to warn employees the product can be flammable, pyrophoric, self-heating, emits flammable gas, self-reactive, or organic peroxides.

• Exclamation Mark: A red diamond with an explanation mark is to warn employees the product can be an irritant (skin or eye), skin sensitizer, acute toxicity (harmful), narcotic effects, respiratory tract irritant, hazardous to the ozone layer (non-mandatory).

• Gas Cylinder: A red diamond with a cylinder. This pictogram warns the employee the product contains gases under pressure.

• Corrosive: A red diamond with two test tubes, with one test tube spilling acid on metal and the other test tube spilling acid on a hand is to warn employees that product can cause skin corrosion/burns, eye damage, or is corrosive to metals.

• Exploding Bomb: A red diamond with an exploding bomb is to warn employees the product can be explosive, self-reactive, or organic peroxide.

• Flame over Circle: A red diamond with a flame on top of a circle is to warn employees that the product is an oxidizer.
• Environment (non-mandatory): A red diamond with a dead tree and a dead fish is to warn employees the product is damaging to the environment including aquatic toxicity.

• Skull & Crossbones: A red diamond with the skull and crossbones is to warn employees the product can have acute toxicity (fatal or toxic).

16 Sections Required on Safety Data Sheet

A Safety Data Sheet, which must be attached to each product which has one or more of the above pictograms, is required to have 16 sections in the following order:

1. Identification
2. Hazard(s) identification
3. Composition information on ingredients
4. First-Aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information, including date of preparation or last revision

OSHA’s revisions of the Hazard Communication guidelines for labeling and safety data sheets will reduce the number of injuries and therefore the number of workers’ compensation claims. Employers are required to comply with the new system by December 1, 2013.

We recommend for employers to review their existing system of hazard communication and to make the necessary changes now to comply with the pictograms and the safety data sheets required by the Final Rule for Hazard Communications. This will allow employers the time needed to train all employees on how to recognize each pictogram and what they will mean within your company. It will also allow employers the time need to change their safety information sheets to comply with the standard format for safety data sheets.

Author Rebecca Shafer, JD, President of Amaxx Risk Solutions, Inc. is a national expert in the field of workers compensation. She is a writer, speaker, and publisher. Her expertise is working with employers to reduce workers compensation costs, and her clients include airlines, healthcare, printing/publishing, pharmaceuticals, retail, hospitality, and manufacturing. She is the author of the #1 selling book on cost containment, Workers Compensation Management Program: Reduce Costs 20% to 50%. Contact:RShafer@ReduceYourWorkersComp.com.

Editor Michael B. Stack, CPA, Director of Operations, Amaxx Risk Solutions, Inc. is an expert in employer communication systems and part of the Amaxx team helping companies reduce their workers compensation costs by 20% to 50%. He is a writer, speaker, and website publisher. www.reduceyourworkerscomp.com. Contact: mstack@reduceyourworkerscomp.com.

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