In March 2012, the Occupational Safety and Health Administration (OSHA) revised the Hazard Communication (HazCom) Standard, 29 CFR 1910.1200, to align it with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), Revision 3. The revision to the HazCom Standard built on the existing standard, by requiring chemical manufacturers and importers to follow specific criteria when evaluating hazardous chemicals and when communicating hazards through labels and Safety Data Sheets (SDSs). The effective compliance date for all employers to train employees on newly identified physical or health hazards is no later than June 1, 2016.
Major changes to the new HazCom standard include:
- Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
- Labels: Chemical manufacturers and importers are required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
- SDS: Updated 16-section format.
- Training: Employers must train workers on the new label elements and safety data sheets format to facilitate recognition and understanding.
How does this change affect RMP and PSM compliance?
The Environmental Protection Agency’s (EPA) Risk Management Program (RMP) regulation, 40 CFR 68, and OSHA’s Process Safety Management (PSM) rule, 29 CFR 1910.119, require all employees, including maintenance and contractor employees, involved with highly hazardous chemicals to be trained on the safety and health considerations of covered chemicals. HazCom Training* is frequently used to meet these requirements and includes:
- Instruction on the hazards in employee work areas,
- Interpretation of the information provided on labels and SDS,
- An understanding on how to access the most current version of SDS, and
- Awareness of the chemical protective measures available in the workplace, how to use or implement these measures, and whom to contact if an issue arises.
Therefore, if HazCom Training is used as one of your compliance methods to protect employees working in RMP and PSM covered processes against chemical-source injuries and illnesses, your program should be in full compliance with the new requirements of 29 CFR 1910.1200.
What can I do to ensure my facility is in compliance?
If you manage RMP and PSM compliance at your facility and you use HazCom to meet part of your training requirements, look closely at your HazCom program. Some key items to check for include:
- Plan: Do you have a written HazCom Program, or safety plan, for your facility? Is it updated as changes take place at your facility (i.e. new chemicals brought onsite)?
- List: Does you facility have a master inventory list of hazardous chemicals?
- Training: Are all employees involved with highly hazardous chemicals, including maintenance and contractor employees, trained on the revised chemical labeling and SDS format?
- Availability: Are all SDS available to employees and do they understand how to access them?
- Labeling: Are all hazardous chemical primary and secondary containers labeled at your workplace with the proper information and pictogram?
How can aeSolutions help?
aeSolutions understands complying with constantly evolving regulatory requirements, international policies, industry best management practices, and corporate requirements can seem overwhelming. We have a range of help to offer from being your outsourced audit solutions partner, developing and implementing a program around your risk management systems, to supplementing your limited process safety resources on an as-needed basis. If you need assistance, please reach out to us through our Contacts page on our website.
*In addition to HazCom Training, additional training around safety and health considerations may need to be covered by an employer’s training program. For a full list of required training review the requirements in the RMP and PSM rules applicable to your facility or contact us and we can help you set up a comprehensive training program.