One of the most commonly cited OSHA citations is the Hazard Communication Program (1910.1200) commonly referred to as HazCom or Employee Right to Know. The program is designed to help employees know and understand the chemical hazards they work with every day. In a cotton gin, we don’t normally think of having chemical hazards but anything that is toxic, carcinogenic, or can burn or otherwise injure you is considered a chemical hazard. Common things we find in a gin are gasoline, oil, grease, hydraulic fluid welding rods etc. In the past we have discussed the need to have proper MSDS’s in you office, and to include the list of chemicals and the location of the MSDS’s in your employee training materials.
This standard has just changed. We’ve known about pending changes to the OSHA rule for a year or so. In the proposed rule, OSHA had discussed some of the changes but the final rule went a bit further. Barry mentioned the proposed rule in our Safety Committee meeting at the past couple of Board Meetings and August safety meetings but since the rule wasn’t final and the main changes were dealing mostly with the MSDS’s we hadn’t made much of a big deal about it. The final rule is now out and we know a lot more about what those changes mean and a timeline for compliance. Don’t worry, the actual changes a bit more involved but the timeline doesn’t begin until the end of 2013.
The most significant changes will be the Safety Data Sheets or SDS’s. These were formerly known as Material Safety Data Sheets or MSDS’s. You will begin getting the new SDS’s in coming months from your suppliers. You may have to ask for them but the suppliers will likely give them to their customers when they get them. In any case you will need to have new ones on file by December 1, 2013. This is also the date you will need to have your employees retrained on the new rules.
The SDS’s will have a very standardized 16 section format. This format is part of the Globally Harmonized System or (GHS) that the UN has been developing. This GHS also prescribes labels for containers of hazardous materials. The labels and SDS’s will have additional information as well as pictograms for better identification of hazards. The pertinent parts of the GHS have been adopted by reference meaning that as the GHS labeling requirements change, so will the labels and SDS’s we have to maintain. The benefit to this new system is that companies that manufacture these chemicals, won’t have to create different SDS’s and labels for different countries that subscribe to the GHS. The additional benefit is that it will better identify the hazards that are associated with a particular chemical.
Over the next few months, we will be combing through the 858 page document that is the new rule. For now just understand that OSHA is focusing on the Hazard Communication program again. It will likely bring additional scrutiny to any business that has an inspection and that changes are coming. As we move forward it wouldn’t hurt to make sure you have identified the hazardous chemicals in your facility. If you shouldn’t drink it or pour it all over your body, then you probably need an MSDS (later an SDS) and add it to your list. The initial compliance date is December 1, 2013. That is the date that you will have to retrain your employees by.
As always, please give us a call and we’ll answer any question as best we can.