Effects of Proposed Label Changes

Q. Our metal finishing facility has an existing hazard communication (HazCom) program that has been in place for many years, with minor revisions made once every four to five years. As with most metal finishing and plating shops, the hazards of most concern involve alkalis, acids, oxidizers, metal-containing solutions, and dust from grinding and polishing. Over the last year, we have received several correspondences regarding the Occupational Safety & Health Administration’s (OSHA) proposal to modify the existing HazCom standard to conform to the United Nations Globally Harmonized System (GHS) of classification and labeling. Could you provide an update on this proposal and a process a metal finishing shop could follow to meet the GHS? S.B.

A. OSHA’s HazCom standard (29CFR1910.1200) has been around since 1983 and is designed to protect more than 30 million American workers exposed to hazardous chemicals in their workplaces. The standard’s main elements include having the following in place:

• Written program
• Material Safety Data Sheets (MSDS)
• Chemical inventory
• Labeling
• Employee training

As the world has become smaller, with shipments of chemicals and products received from all corners of the globe daily, there has become a need for standardization. In 2003, the UN created and adopted the Globally Harmonized System of Classification and Labeling of Chemicals, which includes criteria for the classification of health, physical and environmental hazards, labeling, and safety data sheets. Several countries already have adopted these requirements. In the U.S., OSHA has been in the process of revising its Hazard Communication Standard to be more consistent with the GHS, and in 2009 published a proposed rule-making to align its standard with the GHS. According to OSHA’s regulatory agenda, this rule was supposed to be finalized this past September, so one could expect that the final rule will be issued “soon.” Once the rule is finalized, employers will have three years to implement the new standard.

The most significant impacts upon employers include:
Safety Data Sheets (SDS). The current material safety data sheets (MSDS) will become SDS. These SDS will be required to be developed by chemical suppliers and importers and will have a more standardized format (16 sections) to help employees more quickly and easily find information. The 16 sections include four sections that are not currently required on MSDS: Ecological Information, Disposal Considerations, Transport Information and Regulatory Information.

Container Labeling. The Hazardous Materials Identification System (HMIS), National Fire Protection Association (NFPA) or other labels currently used will be replaced. Manufacturers and importers will be required to provide labels that include standardized signal words (e.g., flammable, explosive, oxidizer, corrosive, etc.), pictograms, and hazard statements that will be assigned to specific hazard categories and classes. In addition to the standardized information, a product identifier, first-aid statements, precautionary statements, manufacturer or supplier information, and other pertinent supplemental information will be required on each label. Once a chemical is brought into the workplace, the GHS-required label must be maintained on the supplied container. This label also can be used for workplace containers (e.g., storage tanks), however it may not be specifically required. Depending on OSHA’s final ruling, employers may be allowed to use alternative written or displayed formats for transmitting hazard information to employees when such a format is more appropriate to the workplace, as long as the format communicates the information as effectively as the GHS label. For example, label information could be displayed in the work area, rather than on individual containers.

Hazard Classification. The current performance-oriented Hazard Communication Standard outlines the expected outcome, but not the specific implementation steps for hazard communication. GHS takes a more detailed approach, specifying the detailed criteria and communication elements for each hazard class, including:

• Health hazards (carcinogen or skin irritant)
• Environmental hazards (acute or chronic aquatic toxicity)
• Physical hazards (flammable, explosive or oxidizing)

Training. Educating employees on the label and MSDS/SDS changes due to the updated product classifications, pictograms, signal words, and hazard and precautionary statements will require the employer to plan ahead and be prepared. Training will be required within two years after the new Hazard Communication Standard goes into effect.

Written Program. Your written hazard communication program will need to be updated to reflect changes made with labeling and SDS.
Here are some websites that may provide you with additional information and guidance as you prepare to update your program:

A Guide to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), commonly referred to as the “Purple Book,” osha.gov/dsg/hazcom/ghsguideoct05.pdf.

The Globally Harmonized System for Hazard Communication background summary, osha.gov/dsg/hazcom/global.html.

In summary, for metal finishing and electroplating facilities, the greatest impact of the GHS will be understanding the new labeling and Safety Data Sheets. In many cases, storage areas and in-house containers will need to be labeled with this information. It may be somewhat of a challenge to determine how to label containers and tanks when a combination of several chemicals, possibly from different suppliers, is used to make up a batch of process chemicals. Once you have a thorough understanding of the Safety Data Sheets and labeling requirements, you will then have the information you will need to revise your written HazCom and training programs.