HazCom 2012 is the first update to the original Hazard Communication standard (HazCom 1994) and aligns the standard to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The parts of the HazCom 1994 that did not relate to the GHS remain largely unchanged.
By now you should have completed the first step of HazCom 2012, employee training. The following table provides an overview of HazCom 2012 and its deadlines.
| Requirement | Description | Deadline |
| Hazard Classification | The hazard determination process has been changed to the hazard classification process. The procedures in Appendices A (health hazards) and B (physical hazards) must be followed. | None listed, but these must be completed to meet the 2015 labelling and safety data sheet deadlines. |
| Labels on Shipped Containers |
HazCom 2012 labels must be in English and include the following information:
- product identifier;
- signal word;
- hazard statement(s);
- pictogram(s) ;
- precautionary statement(s); and
- name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.
New requirements include the signal word, the use of pictograms, and the use of standardized hazard and precautionary statements. The procedures in Appendix C must be followed when generating the label.
|
June 1, 2015 (manufacturers)
December 1, 2015 (distributors)
|
| Workplace Labeling |
Either
- label in accordance with the requirements of labels for shipped containers;
Or
- label or mark with product identifier and words, pictures, or symbols (such as NFPA or HMIS) and ensure that the systems provide employees with specific information regarding the physical and health hazards of the hazardous chemical and do not conflict with GHS.
|
Currently required: HazCom 1994 compliant labels.
June 1, 2016: HazCom 2012 compliant systems.
|
| Safety Data Sheets | The name is changed from Material Safety Data Sheet (MSDS) to Safety Data Sheet (SDS). The SDS must follow a standardized 16-section format that is essentially the same as ANSI Z400.1 / Z129.1-2010, "Standard Hazardous Workplace Chemicals--Hazard Evaluation and Safety Data Sheets and Precautionary Labeling Preparation." | June 1, 2015 (manufacturers)
December 1, 2015 (distributors)
|
| Written Hazard Communication Program | No change | June 1, 2016: complete any update needed to bring written programs into compliance with HazCom 2012. |
| Training and Information | Training in chemical hazards must be provided to employees at the time of initial assignment and whenever a new chemical hazard is introduced into the work area. |
December 1, 2013: training in the new label elements and safety data sheets format.
Ongoing: Initial and periodic training
|
HazCom compliance efforts now shift from employers to manufacturers, who must implement the hazard classification, shipped container labelling, and safety data sheet requirements that are due in 2015. The 2015 deadline also applies to employers who may not typically think of themselves as chemical manufacturers (that is, they produce chemicals or mixtures for use in their own operations). Laboratory employers that ship hazardous chemicals are also considered to be either chemical manufacturers or distributors and thus must ensure that any containers of hazardous chemicals leaving the laboratory are labeled with compliant labels and that SDSs are provided to distributors and other employers as required.
Some manufacturers plan an extended program of updating labels and creating SDS, achieving compliance by the deadline of June 1, 2015, while others are preparing updated SDS and labels now. In fact, STC has already assisted clients with the complicated process of updating SDS by:
- conducting searches for relevant published health and physical hazard data;
- using the processes detailed in the appendices of the standard to identify hazards and assign the signal word, pictogram(s), and hazard and precaution statements;
- combining this information with any additional sources (such as shipping information and applicable regulations) to complete the remaining sections of the SDS; and
- generating the completed GHS-compliant SDS.
Employers now have a compliance interlude between December 1, 2013 (training) and the final deadline of June 1, 2016, when they must fulfill all provisions of HazCom 2012. Proactive employers will use this time to review their current written program and begin the process of updating non-compliant provisions. They will also examine current MSDS management systems to determine if they can handle the large numbers of updates expected over the next few years or if they need to be replaced. Finally, employers should begin assessing workplace label systems and updating as needed.
All groups impacted by HazCom 2012--manufacturers, distributors, and employers--should take advantage of the implementation period provided by OSHA to update the provisions of their hazard communication programs to meet the revised standard. If your organization needs help in meeting your hazard communication challenges, STC invite you to draw on our expertise in training, labeling systems, and authoring GHS-compliant SDSs.
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. Carol has been providing GHS employee training and assisting in the authoring of GHS-compliant SDS to a number of STC clients. 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.
