Global Harmonization What?
If you haven’t heard by now, new rules have gone into effect on how you train employees or yourself on the new safety data sheets. Just in case you have not heard this, I thought I would share with you some information from TASB and NPMA on the changing of MSDS to SDS and who needs to be trained. Today we had our Fall IPM Seminar at the Texas A&M AgriLife Research and Extension Center in Dallas. One of our speakers was Dr. Don Renchie, who covered this topic with close to 300 applicators from the North Texas region – in short, we all need to be aware of this new rule and adhere to it. If you are applying pesticides – please remember to review the new rules and train your staff.
Federal Hazard Communication Rules
By: Joanie Arrott, Risk Management, TASB
The Hazard Communication Standard (known as HazCom for short) was originally adopted by the Occupational Safety & Health Administration (OSHA) in 1984. The HazCom Standard is also known as the Worker’s Right to Know Act, based on the fundamental premise of the standard which is that employees have the right to know about the hazards they can be affected by in the workplace. The complete federal standard can be found at 29 CFR 1910.1200.
In early 2012, OSHA began the process of aligning the HazCom Standard with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Prior to the implementation of GHS, chemical manufacturers and distributors were allowed to present information on chemical labels and Material Safety Data Sheets (MSDS) in whatever format they chose. Once fully implemented, the new standards will lead to enhanced workplace comprehension of hazards, reduced confusion, facilitated training, and safer handling of chemicals. Workplace employees will have quicker and more efficient access to hazard information.
Revised HazCom Standard
As a result of the HazCom rules being aligned with the GHS, there are three major areas of change: hazard classification, labels, and safety data sheets.
The newly revised HazCom standard includes a common and coherent approach to classifying chemicals and communicating hazard information that was developed. The definitions of hazards have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result.
Chemical manufacturers and distributors will be 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. This means that all chemical manufacturers and distributors must prepare new labels and safety data sheets to convey the hazard information to their downstream customers.
Employers must ensure that new labels and safety data sheets are compiled and used throughout the workplace. Chemical labels using the old format of hazard information and MSDS will not be allowed.
Employers must ensure that the SDSs are readily accessible to employees for all hazardous chemicals in their workplace. This may be done in many ways. For example, employers may keep the SDSs in a binder or on computers as long as the employees have immediate access to the information without leaving their work area when needed and a back-up is available for rapid access to the SDS in the case of a power outage or other emergency. Furthermore, employers may want to designate a person(s) responsible for obtaining and maintaining the SDSs. If the employer does not have an SDS, the employer or designated person(s) should contact the manufacturer to obtain one.
Important Compliance Deadlines
December 1, 2013 – Employers must train employees on the new label elements and safety data sheet (SDS) format
Workplaces are already receiving labels and SDSs that are consistent with the GHS, since many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDSs. It is important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they will be familiar with them, understand how to use them, and access the information effectively.
December 1, 2015 – Chemical manufacturers, distributors, importers, and employers must ensure all containers are labeled using the GHS label standards.
During the phase-in period, employers would be required to be in compliance with either the existing HCS or the revised HCS, or both. OSHA recognizes that hazard communication programs will go through a period of time where labels and SDSs under both standards will be present in the workplace. This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.
June 16, 2016– Employers must be fully compliant with GHS standards. This means all required employees receive the necessary training for the GHS standards, and all records and all products must be identified with GHS SDS’s and labels.
This will not change how districts conduct business, but it will impact the district’s HazCom Plan and Chemical Hygiene Plan in that training will need to be given on how to read the GHS SDS’s and labels as well as updating all chemical inventories with the proper SDS’s and labels. Remember the deadlines for the rule; this is a four year adoption process to become fully compliant. There is a sample GHS SDS and label attached to this message for your review. Below are a few links and resources that can also answer questions that you may have.
Resources and Links
For an overview of the 2012 update to the Hazard Communication Standard, NPMA created a library update for our PESTWORLD magazine. NPMA also created an online training that meets the December 1, 2013 OSHA specific training requirements. These items are accessible at the following link: http://www.npmapestworld.org/publicpolicy/hazcomm.cfm
ALL pest management professionals including technicians and apprentices that handle pesticides are required to undergo the updated training.
OSHA’s FAQ on GHS compliance: http://www.osha.gov/dsg/hazcom/hazcom-faq.html#1
United Nations Globally Harmonized System of Classification and Labeling of Chemicals- Fourth revised edition: http://www.unece.org/trans/danger/publi/ghs/ghs_rev04/04files_e.html
MSDS online GSHS answer center: http://blog.msdsonline.com/ghs-answer-center/
Thank you to George Scherer with TASB’s OnSite Environmental as well for sharing his thoughts on this topic. As well as Marcia Duke with the National Pest Management Association