How is the HazCom Standard related to the Globally Harmonized System?

OSHA's HazCom standard dates back to 1983, when it was often referred to as the Right-to-Know (RTK) rules. They were updated and revised many times over the years, but in 2003, the United Nations adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

Unfortunately, the US's specific RTK rules often conflicted with the GHS. This caused trouble, expense, and barriers for any chemicals traded internationally, since businesses had to go to the trouble of meeting two sets of rules that weren't consistent.

So in 2012, OSHA created the current version of the HCS to bring them into alignment with the GHS. Employers were given until 2016 to fully transition, but many did so ahead of time since it simplified their compliance.

OSHA's HCS isn't identical to the UN's GHS. That's because the HCS is an OSHA rule, and the GHS addresses issues that don't fit until OSHA's workplace safety jurisdiction (like environmental hazards). On the flip-side, the GHS fails to address certain safety concerns that the HCS does.

So OSHA didn't adopt the GHS wholesale. However, the HCS is now very consistent with the GHS in their overlapping requirements, like classification, labeling, Safety Data Sheets (SDSs), and worker training.

Who Has Hazard Communication Duties?

Chemical manufacturers, importers, and distributors are responsible for hazard classification under OSHA's GHS-aligned HCS. They're responsible for classifying the hazards a chemical presents, then preparing labels and Safety Data Sheets.

Hazard Classification

The hazard classification system is broken into health hazards and physical hazards. Physical hazards include chemicals that are explosive, flammable, oxidizing, self-reactive, corrosive to metal, and more. Health hazards include things like carcinogenicity, various types of toxicity, simple asphyxiants, and more.

These defined "hazard classes" are divided into "hazard categories," which are directly related to the information on labels and SDSs.

Any hazardous chemicals that don't meet a defined classification are designated as Hazards Not Otherwise Classified (HNOC). The SDSs for HNOC chemicals must include their effects and appropriate protective measures.

Hazard Labels

The HCS/GHS requires manufacturers, importers, and distributors to place a label on each container before shipping.

These are supposed to give an immediate hazard warning with requirements like:

• the product identifier
• a signal word (like "danger" or "warning") that indicates hazard severity
• a hazard statement outlining the nature and degree of the hazard in a simple, direct manner (like "fatal if swallowed" vs "harmful if swallowed")
• a pictogram classifying the hazard
• a precautionary statement describing recommended safety measures for prevention, response, storage, and disposal
• the contact information of the responsible party

Safety Data Sheets (SDSs)

Safety Data Sheets contain detailed information on a chemical's hazards. Under HCS/GHS guidelines, it must include 16 standardized sections like ingredients, first aid measures, handling and storage, and more.

An SDS has to be provided with the first shipment of any chemical, and a new one must be provided anytime the SDS is updated.

What are an Employer's Hazard Communication Duties?

OSHA's GHS-aligned Hazard Communication Standard requires you to execute certain duties as an employer that simply uses chemicals in the workplace without producing or importing them.

An employer's duties include preparing and implementing a written hazard communication program, ensuring that label and SDS rules are met, training employees on required topics, making additional information available to them, and creating processes for maintaining the HazCom program.

A Written HazCom Program

OSHA requires a written hazard communication program that covers how your workplace will comply with all requirements. You can find templates online to help you create the document, but it needs to be tailored to reflect what you're actually doing on-site.

The written program is more than just a formality – it gives you the opportunity to think through how you'll comply with OSHA's HCS rules.

A compliant written program will include:

• How you'll address
  • the Labeling/Warning requirements in 1910.1200(f)
  • the SDS requirements in 1910.1200(g)
  • the Employee Information and Training requirements in 1910.1200(h)
• Who, specifically, is responsible for compliance in each area
• Processes for checking compliance and updating materials
• A complete list of hazardous chemicals known to be present in the workplace
• How you'll inform workers of chemical hazards they might encounter outside their normal work routine

In multi-employer workplaces, the written HazCom program needs to specify who is responsible for what and how information will be exchanged.

Labeling and SDSs

Employers can rely on the label and SDS information provided by manufacturers and other upstream parties. However, employers need to ensure their availability and continued use by:

• Ensuring that all immediate containers with hazardous chemicals in the workplace bear the required label, legible and prominently displayed. Often this means using the shipping container, but if chemicals are transferred to a new container, they need to be relabeled.
• Maintaining Safety Data Sheets for each hazardous chemical in the workplace. If you don't receive one from your upstream source or it's incomplete, you need to request a new one right away. If an updated SDS is provided, you need to make it available.
• Making SDSs accessible to workers in a manner appropriate to your workplace. This may involve a binder in a central location or electronic access. Any workplace that uses electronic SDSs needs to maintain a hardcopy backup as well.

HazCom Training for Workers

None of the HCS requirements we've discussed are useful unless workers know about them, so another required component is to train and inform your workers.

Employees need to be "informed" of certain information but "trained" on other information. Training is a more in-depth process.

All employees in workplaces with hazardous chemicals need to be informed of:

• The general requirements of OSHA's Hazard Communication Standard.
• Where hazardous chemicals are located in their areas, as well as operations where exposure could occur.
• The workplace hazard communication program's pieces, as well as where and how they can access the written program.

Workers need to be trained if they'll be exposed to hazardous chemicals under normal working conditions .  Training needs to occur before their initial assignment to a work area with hazardous chemicals and whenever new hazards are introduced. This means a new type of hazard – additional training isn't necessarily required for each new chemical.

Training needs to cover:

• How to tell that a hazardous chemical is present or has been released in the work area
• The hazards presented by chemicals in their work area
• How to protect themselves against these hazards, including appropriate work practices, emergency procedures, and personal protective equipment to use
• HazCom labels and their meaning
• What an SDS is and where important information can be located in the document
• How to find and use additional hazard information

While some aspects of training need to be workplace-specific, like the specifics of your labeling system or where to find an SDS, the basics are often very similar.

Using off-the-shelf training solutions like ours can lighten the burden of OSHA compliance by ensuring that workers get effective, up-to-date training on essential information.

Check out our GHS training solutions and GHS/OSHA HCS online worker training course for help with your Hazard Communication Standard training!