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December 1, 2013 Training Requirements for the Revised Hazard Communication Standard
11/19/2013

OSHA revised its Hazard Communication Standard (HCS) to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Two significant changes contained in the revised standard require the use of new labeling elements and a standardized format for Safety Data Sheets (SDSs), formerly known as, Material Safety Data Sheets (MSDSs). The new label elements and SDS requirements will improve worker understanding of the hazards associated with the chemicals in their workplace. To help companies comply with the revised standard, OSHA is phasing in the specific requirements over several years (December 1, 2013 to June 1, 2016).

The first compliance date of the revised Hazcom Standard is December 1, 2013. By that time employers must have trained their workers on the new label elements and the SDS format. This training is needed early in the transition process since workers are already beginning to see the new labels and SDSs on the chemicals in their workplace. To ensure employees have the information they need to better protect themselves from chemical hazards in the workplace during the transition period, it is critical that employees understand the new label and SDS formats.

The list below contains the minimum required topics for the training that must be completed by December 1, 2013.

Training on label elements must include the following information.

• The type of information an employee would expect to see on the new label.

• Product identifier: how the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS.

• Signal word: used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. There are only two signal words, “Danger” and “Warning.” Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. There will only be one signal word on the label no matter how many hazards a chemical may have.

• Pictogram: OSHA’s required pictograms must be in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame sufficiently wide enough to be clearly visible. A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label. OSHA has designated eight pictograms under this standard for application to a hazard category.

• Hazard statement(s): describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. All of the applicable hazard statements must appear on the label. Hazard statements may be combined where appropriate to reduce redundancies and improve readability. The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it.

• Precautionary statement(s): means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.

• Name, address and phone number of the chemical manufacturer, distributor, or importer.

• How an employee might use the labels in the workplace.

• Explain how information on the label can be used to ensure proper storage of hazardous chemicals.

• Explain how the information on the label might be used to quickly locate information on first aid when needed by employees or emergency personnel.

• General understanding of how the elements work together on a label.

• Explain that where a chemical has multiple hazards, different pictograms are used to identify the various hazards. The employee should expect to see the appropriate pictogram for the corresponding hazard class.

• Explain that when there are similar precautionary statements, the one providing the most protective information will be included on the label.

Training on the format of the SDS must include the following information.

• Standardized 16-section format, including the type of information found in the various sections.

• How the information on the label is related to the SDS.

For more information on the revised Hazcom Standard, including labeling, pictograms, safety data sheets and a list of frequently asked questions visit: http://www.osha.gov/dsg/hazcom/index.html.