The change the EHS community waited for has finally arrived. In March 2012, OSHA released the updated Hazard Communication Standard (HCS) that adopts the Globally Harmonized System (GHS). This international system of hazard communication brings a consistent approach to hazard classification (formerly hazard assessment), labeling, and safety data sheets (formerly material safety data sheets).

Several of the previous HCS requirements remain unchanged. The standard still requires a GHS has not changed  a written hazard communication program. The training requirements under the updated HCS remain similar to the previous version except that training must be expanded to cover all hazards in the revised definition of hazardous chemical, along with explanations of safety data sheets and labeling for shipped containers and in workplaces. The trade secret provisions of the HCS also remain the basically the same, although manufacturers may now claim the exact percentage (concentration) of the substance in a mixture as a trade secret.

The updated HCS does include significant changes under GHS, on the other hand, include the definition of hazardous chemical, product labels, and safety data sheets. These changes have been adopted to harmonize the HCS with GHS requirements.

Definition of Hazard Chemical 

"Hazardous chemical" was previously defined as a chemical that was a physical or health hazard. The revised definition includes physical hazard, health hazard, simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.  

"Physical hazards" are chemicals with at least one of the following hazardous attributes: 

• explosive;
• flammable (gases, aerosols, liquids, or solids);
• oxidizer (liquid, solid, or gas);
• self-reactive;
• pyrophoric (liquid or solid);
• self-heating;
• organic peroxide;
• corrosive to metal;
• gas under pressure; or
• when in contact with water, emits flammable gas.

"Health hazards" are chemicals with at least one of the following hazardous attributes: 

• acute toxicity (any route of exposure);
• skin corrosion or irritation;
• serious eye damage or eye irritation;
• respiratory or skin sensitization;
• germ cell mutagenicity;
• carcinogenicity;
• reproductive toxicity;
• specific target organ toxicity (single or repeated exposure); or
• aspiration hazard. 

The revised HCS has specific criteria for each health and physical hazard, along with detailed instructions for hazard evaluation and determinations as to whether mixtures or substances are covered. Appendix A provides the detailed Health Hazard criteria, including the toxicity classifications (from 1, most hazardous, to 4, least hazardous) and the mandatory principals for classifying mixtures. Appendix B contains the Physical Hazard criteria. Both Appendix A and Appendix B are mandatory.

Product Labels 

The most notable change in product labeling is that the "appropriate hazard warning" requirement has been replaced and expanded. Under the new HCS standard, product labels on shipped containers must include the following:

• Product identifier (as before);
• Signal word;
• Hazard statement(s);
• Symbols (hazard pictogram(s));
• Precautionary statement(s); and,
• Name and address of the chemical manufacturer, importer, or other responsible party (as before), as well as that party's telephone number.

The new HCS standard incorporates the GHS standardized signal words, hazard statements and pictograms to convey the health, physical and environmental hazard information assigned to each GHS hazard class and category. Workplace labels may include the same the labeling information as used on shipped containers. Alternatively, workplace labels may include the "product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical" (29 CFR 1910.1200(f)(6)(ii)). The new standard continues to allow signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers.

Many employers have effectively used the National Fire Protection Association (NFPA) 704 Hazard Rating and Hazardous Material Information System (HMIS) for workplace labeling. According to OSHA, employers may continue to use these labeling systems for workplace containers; "[h]owever, the information supplied on these labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms" (OSHA Frequently Asked Questions). The confusion comes from the different approaches to numerical ratings: under GHS, the more severe the hazard, the lower the hazard number; in contrast, under NFPA/HMIS systems, the greater the severity, the higher the hazard number. Such labeling is particularly an issue when chemicals are transferred from the received supplier-labeled container into a secondary container such as a chemical wash bottle, transfer container, or piping or for labeled pure chemicals or mixtures produced in laboratories or manufacturing intermediates. Now that the HCS update has been released, we can expect both NFPA and the American Coatings Association to address the continued use of their existing labeling systems under the new HCS.

Safety Data Sheets 

Safety Data Sheets (SDS) will now require a 16-section format that is essentially the same as the ANSI standard Hazardous Workplace Chemicals-Hazard Evaluation and Safety Data Sheets and Precautionary Labeling Preparation (ANSI Z400.1/Z129.1-2010). The standardized sections of the SDS include the following:

• Section 1, Identification;
• Section 2, Hazard(s) Identification;
• Section 3, Composition/Information on Ingredients;
• Section 4, First-aid Measures;
• Section 5, Fire-fighting Measures;
• Section 6, Accidental Release Measures;
• Section 7, Handling and Storage;
• Section 8, Exposure Controls/Personal Protection;
• Section 9, Physical and Chemical Properties;
• Section 10, Stability and Reactivity;
• Section 11, Toxicological Information;
• Section 12, Ecological Information;
• Section 13, Disposal Considerations;
• Section 14, Transport Information;  
• Section 15, Regulatory Information; and 
• Section 16, Other Information, including date of preparation or last revision.

While the headings for Sections 12 - 15 are required, OSHA announced that it will not enforce the information requirements of these sections. OSHA did retain the requirements to include Permissible Exposure Limits, American Conference of Government Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), International Agency for Research on Cancer (IARC) classifications, and National Toxicology Program (NTP) listings on SDSs.

HCS requires labels and SDSs to be in English, although other languages are permitted in addition to English. (Training must be provided in a language understood by the employees.) The employer must maintain copies of SDSs and ensure they are available to employees; electronic copies are acceptable as long as they are readily accessible.

Compliance Tasks and Deadlines 

The changes to the HSC will require significant efforts on the part of chemical manufacturers, importers, distributors, and employers. OSHA has therefore established a phased-in approach to compliance (the implementation table below was extracted from the agency's Frequently Asked Questions page). Chemical manufacturers must start by reclassifying all chemicals in accordance with the new hazard classification criteria and creating compliant Safety Data Sheets and new product labels. For employers, the most immediate focus is employee training on the Safety Data Sheet format and new label elements.

A side by side comparison of the existing HCS to the revised HCS is available on OSHA's Hazard Communication page (http://www.osha.gov/dsg/hazcom/side-by-side.html)

STC is ready to help update written Hazard Communication programs, lead in-house training, and provide other HCS assistance to our clients as these changes take effect.

Carol Robinson, CIH, CSP, and STC Vice President, is located in Oakland, CA. She has over 30 years experience in EHS management and consulting for a wide range of industries including biotech, chemical, high tech, personal care, and petrochemical companies. Carol assists clients with EHS management systems implementation, standards and procedures development, and auditing programs. She has developed registries of requirements, performed hazard and exposure assessments, and conducted compliance and management system audits to provide clients with the data needed to understand their compliance status. She has also helped clients identify and implement practical corrective and preventive actions. As head of corporate EHS programs at JDS Uniphase and Helene Curtis, Carol developed corporate objectives, metrics, policies, and strategic direction. Her experience managing non-EHS groups-including engineering, facilities, corporate security, and TSCA compliance-has exposed her to a diverse range of business issues and backgrounds, enabling her to provide focused, understandable, and actionable guidance and training.

For more information about GHS and STC's health and safety consulting services, contact Carol Robinson at (510) 495-6070 or crobinson@stcenv.com.