U.S. Adopts New Hazard Communication Standard

GHS, the United Nations’ globally harmonized system of classification and labeling of chemicals, has been adopted by the United States. There are two significant changes in this revised standard: One, it requires the use of new labeling elements. Two, it requires a standardized format for Safety Data Sheets (SDSs), formerly called Material Safety Data Sheets (MSDSs).
Many countries already have regulatory systems in place for these types of requirements including the United States. Although these systems may be similar in content and approach, their differences were enough to make working between different countries and different regulating agencies difficult and sometimes confusing for manufacturers and users. This led to inconsistent protection for those potentially exposed to the chemicals which was why these types of systems were created in the first place.
The standard we have been using for years, Hazard Communication Standard (HCS) has been modified to align with the GHS. There are two significant changes in the revised standard: One, it requires the use of new labeling elements and two, it requires a standardized format for Safety Data Sheets (SDSs), formerly called Material Safety Data Sheets (MSDSs). The new label elements and SDS requirements are supposed to improve worker understanding of the hazards associated with the chemicals in their workplace. Public employers should be training their workers on the new label elements and the SDS format. This training is needed early because workers are already beginning to see the new labels and SDSs on the chemicals in their workplace. To ensure employees have the information they need to better protect themselves from chemical hazards in the workplace during the transition period, it is important that employees understand the new label and SDS formats.
The list below contains the minimum required topics for the training: Training on label elements should include information on the type of information an employee can expect to see on the new labels:
• Product identifier: How the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS (Identification).
• Signal word: Used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. There are only two signal words, “Danger” and “Warning.” Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. There will only be one signal word on the label no matter how many hazards a chemical may have. If one of the hazards warrants a “Danger” signal word and another warrants the signal word “Warning,” then only “Danger” should appear on the label.
• Pictogram: The Federal government has designated eight pictograms under this standard for application to a hazard category.
• Hazard statement(s): Describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.” All of the applicable hazard statements must appear on the label. Hazard statements may be combined where appropriate to reduce redundancies and improve readability. The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it.
• Precautionary statement(s): A phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.
• Name, address and phone number of the chemical manufacturer, distributor, or importer
The employees should be given some examples of how they might use the new labels. Some examples are below:
• Explain how information on the label can be used to ensure proper storage of hazardous chemicals.
• Explain how the information on the label might be used to quickly locate information on first aid when needed by employees or emergency personnel. The employees should have a basic understanding of how the elements work together on the new labels. For example,
• Explain that where a chemical has multiple hazards, different pictograms are used to identify the various hazards. The employee should expect to see the appropriate pictogram for the corresponding hazard class.
• Explain that when there are similar precautionary statements, the one providing the most protective information will be included on the label. Training on the format of the SDS should include information on:
• Standardized 16-section format, including the type of information found in the various sections.
   o For example, the employee should be instructed that with the new format, Section 8 (Exposure Controls/Personal Protection) will always contain information about exposure limits, engineering controls and ways to protect you, including personal protective equipment.
• How the information on the label is related to the SDS.
   o For example, explain that the precautionary statements would be the same on the label and on the SDS.
If your entity needs this training, please contact your Risk Control Consultant to assist you.