It’s almost as inevitable as death and taxes…the regulations affecting your business will be changing (again) soon. Specifically, this time, OSHA plans to align the Hazard Communication Standard (HazCom or HCS per 29 CFR 1910.1200) with the United Nations Global Harmonized System (GHS) Revision 7. Although the UN Committee of Experts publishes updated versions of the GHS every two years, the US HazCom Regulations were last updated in 2012 and are still based on GHS Revision 3. In comparison, Canada has adopted GHS Revision 5 and, as of October 2018, Mexico has implemented GHS Revision 6. Such (seemingly small) variations can cause border delays when transporting hazardous materials and, more importantly, frustrated customers! This is in addition to the more immediate need to assure your Written Program, SDS files and training are in-compliance with the latest HazCom Standard to avoid safety issues and OSHA violations. For now, the current HazCom 2012, with its GHS Revision 3 aligned requirements remains the law of the land until OSHA communicates differently. OSHA is expected to release its notice of proposed rulemaking (NPRM), in February, 2019.
So, what’s new in Revision 7 that you might start preparing for?
- Updated definitions for some health hazard classes. The definitions of skin corrosion, skin irritation, serious eye damage, eye irritation, dermal corrosion, dermal irritation, respiratory sensitizer, specific target organ toxicity, reproductive toxicity, and carcinogenicity are all slightly updated for additional clarity.
- Modified criteria for how flammable gases are categorized. Prior to Revision 7, there was ambiguity regarding how to apply categories provided in the flammable gas chapter. Now, to eliminate some of the confusion, both pyrophoric gases and chemically unstable gases meet the classification criteria of the flammable gases category 1A. Also, two hazard statements are now assigned to pyrophoric gases and chemically unstable gases category 1A/1B.
In addition, some of the changes which are likely due to the interim GHS revisions include:
- New hazard categories for chemically unstable gases and non-flammable aerosols (Rev. 4)
- Further clarification of criteria to avoid differences in the interpretation of precautionary statements (Rev. 4)
- Addition of a new test method for oxidizing solids (Rev. 5)
- Revised/simplified classification & labelling summary tables (Rev. 5)
- New codification system for hazard pictograms (Rev. 5)
- New hazard class for desensitized explosives (Rev. 6)
- New hazard category for pyrophoric gases (Rev. 6)
- Additional information to be included in Section 9 of safety data sheets (SDSs) (Rev. 6)
Chemical manufacturers, importers, distributors and employers of facilities where hazardous materials are used and stored should review their SDS libraries now to ensure they have the most updated information available for employees to access, verify shipped labels and workplace container labels comply with GHS, update written HazCom plans, and make sure all employees have been trained to comprehend the current GHS changes.
Employers should be prepared to manage against another phased-in deadline and the consequential SDS library influx resulting from updated documents arriving with any initial shipments from suppliers or with first shipments following significant changes made to the documents.
A well-organized, up-to-date chemical inventory will also help ease the transition to GHS Revision 7 and provide you with valuable insight as to what chemicals you currently have so you can understand how any hazard reclassifications will affect your business.
By taking a few measured steps, safety professionals can begin to lay the groundwork for any future changes to come while improving their hazard communication management right now.