Health & Safety: Revised OSHA Hazard Communication Standard Improves Chemical Label Information–Changes You Need to Know
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Contributors to this page: Health and Safety Committee, Michael Hunt, CIH, Industrial Hygienist with the Smithsonian Institution's Office of Safety, Health and Environmental Management, Corey Smith Riley (Original Guide Authors); Kerith Koss Schrager
This article originally appeared as a special Health & Safety Guide in AIC News--and may have been updated
Revised OSHA Hazard Communication Standard Improves Chemical Label Information –Changes You Need to Know
Date: March 2014
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Revised OSHA Hazard Communication Standard Improves Chemical Label Information –Changes You Need to Know[edit | edit source]
In 2012, OSHA revised its Hazard Communication Standard (29 CFR 1910.1200) to align it with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The basic worker Right-to-Know provisions remain: every manufacturer and importer must still evaluate their chemicals and provide hazard information to employers and workers on labels and material safety data sheets (now called Safety Data Sheets); employers must still train their workers in these hazards and how best to protect themselves from injury or illness by using the chemicals safely.
However, the revised standard now specifies more detailed label information, including the use of pictograms and quick visual notations, to provide more immediate hazard recognition and enhanced worker comprehension (regardless of language barriers). Labels now also must provide instructions (with pictograms where appropriate) on how to handle the chemical so users are clearly informed on how to protect themselves with every real-time use. Chemicals are now classified on a standard international scheme, resulting in hazard information that is consistent world-wide.
The AIC Health and Safety Committee has collected information here to familiarize you with these important changes and the wealth of detailed facts that will be on new Safety Data Sheets and container labeling. All users of chemicals in a workplace (including employees, volunteers, interns, visiting scientists, contractors working around your chemicals) were to have already received training from their employer as of December 1, 2013. Private practice conservators need to self-train, and can find a host of valuable training tools and fact sheets that easily explain each change on OSHA’s web site (see section 1.2).
Why the Change? What will Labels and Pictograms look like?[edit | edit source]
by Michael Hunt, CIH, Industrial Hygienist with the Smithsonian Institution’s Office of Safety, Health and Environmental Management.
In the year and a half since the U.S. Department of Labor (DOL) changed the Federal OSHA Hazard Communication standard (HazCom), conservators have been asking their industrial hygienists and other safety professionals many pertinent questions; such as “what are these new pictograms” and “why would OSHA change one of the most successful safety standards?” Sometimes with less pleasure, we get asked “why is retraining of our staff necessary,” which is usually accompanied with the rejoinder “this is very time consuming.” The old HazCom standard had, after all, been a linchpin of Museum safety programs for almost 20 years. Why the need for a change? The answer to these questions is that the core changes to the standard (e.g., the new labels and pictograms) are really all about symbols and their power to communicate; and more specifically the need for symbols to communicate safety information in a standardized fashion across international borders.
Consider the new skull and crossbones pictogram, which references a chemical product having acute toxicity. This symbol already has some cultural significance; possibly evoking images of pirates, and walking the plank. Because many of us probably read Treasure Island as children and are familiar with this symbol, we can surmise that we need to be careful when handling this product. However, when we look at the other eight new pictograms, such as the exclamation mark pictogram, or the health hazard pictogram, their meaning may be unclear without training. What purpose could be served by creating new unclear symbols? To understand, you have to consider the challenges caused by the numerous country-specific safety labels and symbols within the context of an increasingly trans-national world. Consider the now retired European Union “harmful” symbol (a simple X in a box). A local U.S. chemical manufacturer was required to apply this symbol on the labels of certain products bound for France, knowing that the message would be lost on its American audience. Conversely, Americans working in foreign countries would purchase chemicals whose labels might not contain any hazard warning information at all, or be classified with unrecognizable international hazard symbols. Over time, it seems, the classification and labeling of chemical products has evolved differently throughout the World. Would it not be better to create one standard set of symbols and labels?
At the 1992 Earth Summit in Rio De Janeiro, it was decided to harmonize the classification and labeling of chemicals. After considering the weaknesses and strengths of the various symbols, the technical committee responsible for the revision settled on standard language which they disseminated in the guise of the “UN Purple Book”. The United Nations (UN) recommended that the new standardized classification and labeling scheme be adopted by countries without standards. Where standards were already present, such as here in the US, the UN suggested that the existing standards be “harmonized” with the recommendations of the Purple Book. The DOL agreed to follow suit with the UN recommendations, and after six years in the rulemaking process, promulgated the new HazCom standard in March 2012. Manufacturers will be expected to comply with all modified provisions of the final rule by June 2015. Worker training was to have been completed last December 2013, however, because these new symbols are already being used throughout the world.
Conservators need to be cognizant of the 3 major “communication” changes: label requirements, pictograms and updated Safety Data Sheets. Labels for a hazardous chemical must contain (see Fig 1):
- Manufacturer or importer contact information (name, address, telephone).
- Product Identifier (code or batch number, also listed on SDS Section 1).
- Signal Words, and there are only 2: “Danger” for severe hazard or “Warning” for less severe.
- Hazard Statement, describing the hazard nature and degree, per classifications listed in the Standard and its Appendices. For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.”
- Precautionary Statements describing recommended measures to be taken to minimize/prevent adverse effects from exposure or improper storage or handling. There are 4 types: prevention, emergency response, storage and disposal. The manufacturer may also include supplementary information, such as gloves-needed or percentage of some highly toxic ingredient.
- Pictograms: graphic symbols communicating the hazard, conforming to GHS and used world-wide.
Figure 1.Sample Label[edit | edit source]
It is going to take a little while to get used to the nine new pictograms(See Fig 2). In addition to the skull and crossbones, health hazard, and exclamation mark pictograms, there are pictograms to represent products toxic to aquatic life, explosives, oxidizers, gases under pressure, corrosives, and flammables.
It is worth pointing out that there is some firm logic behind these pictograms (outlined in Appendix C of the Haz Com Standard). Like a teenager sorting baseball cards, chemical products are sorted with the appropriate pictograms, depending on the chemical properties or toxicology of the product. For example, a manufacturer of toluene will need to apply a flammable pictogram to their container label because the flash point and boiling point of the chemical lie within the range of flammable category #2 (i.e., flash point < 73.4F, boiling point > 95F).
Figure 2. Pictogram Hazards[edit | edit source]
The third major change to the HazCom Standard: we’ll just get used to pulling out Safety Data Sheets (SDS’s) instead of Material Safety Data Sheets (MSDS’s) with your chemical shipments. OSHA has essentially adopted an ANSI standard which specified a 16 section MSDS format. The new SDS also aligns with the pictogram and label information changes on the matching chemical container.
HazCom 2012 and the changes to chemical labeling for conservators in a small private practice.[edit | edit source]
by Corey Smith Riley, Riley Art Conservation Services, Raleigh, NC.
As a conservator in a small private practice, I do not legally fall under the OSHA training regulations in regards to the new labeling system nor do I have an organized training that was required by December 1, 2013. This is not an excuse to be uninformed on the HazCom 2012 label changes on some chemicals shipped today and required on all chemicals shipped after June 1, 2015. Even without a formal in-person training, conservators such as myself can easily become educated about the changes to chemical labeling and the new pictograms from three very valuable links on the GHS (Globally Harmonized System) page of the OSHA website. I encourage any conservator in a small practice that does not have official training provided for them to take a look at the following resources, which are listed below in order of usefulness.
1. OSHA Brief on Labels and Pictograms. This nine page pdf is extremely valuable in explaining the new labeling elements, identifying what goes on a label and describing what the new pictograms are and how to use them. We will also have hard copies of this document at the Health and Safety Committee booth at the 2014 annual meeting in San Francisco.https://www.osha.gov/Publications/OSHA3636.pdf
2. Downloadable 2013 Hazard Communication Presentation. This 61 slide powerpoint presentation on “Hazard Communication Standard 2012: One Year of Implementation” essentially provides the full training on the labeling changes that you would receive in an official OSHA training class. The presentation is geared towards the trainers teaching the new standards classes and includes information on 2013 training requirements, updates on implementation issues, and resources for compliance. This presentation also includes information on the changes to the new 16-section safety data sheets (SDS’s) that will replace MSDS’s.https://www.osha.gov/dsg/hazcom/webinar/schc_webinar_72513_clean.pptx
3. Downloadable Hazard Communications 2012 Presentation. This 61 slide powerpoint presentation highlights the differences between the HazCom 1994 standards and the HazCom 2012 standards, and covers what changes can be expected in the workplace. These comparisons are presented in a clear, bullet point form. The presentation also includes a list of effective dates for HazCom 2012 implementation.https://www.osha.gov/dsg/hazcom/schc_alliance_webinar_20120809/schc_alliance_webinar_20120809.pptx
Employer Responsibilities for Updating Labels and SDS before June 1, 2016.[edit | edit source]
The effective dates of the new standard (See Fig 3) range from employee training(December 1, 2013) to manufacturer updating/modifying their labels and SDSs(June 1, 2015) to complete compliance by employers and users for having updated labels on containers and new SDSs on file. OSHA realizes that there will be a transition period in which you may have chemicals with both the old and new labels formats.
However, as soon as you or your employer begin receiving new SDSs or other updated hazard information, you must share that information with all employees so they are properly trained until a new order of that chemical arrives, with its updated GHS label.
To bridge the information gap between current older labels on your shelves, we recommend that you pro-actively obtain new SDSs now by calling the manufacturer or looking on their website. Most websites post all the SDSs. Be sure that you are obtaining the correct SDS for exactly the chemical on your shelf! Many have various additives or formulations, so double-check. When in doubt, call the company directly.
In addition, employers may continue to use rating systems such as the National Fire Protection Association(NFPA) diamond or Hazardous Materials Identification System (HMIS) requirements for workplace labels, as long as they are consistent with the requirements of the Hazard Communication standard and employees have the same immediate access to specific hazard information (i.e., new labels, SDSs, pictograms).