We have discussed the new Hazard Communication standard and how to implement the program in past articles. The process started back in 2013 with the first deadline for training on the new SDS and label formats. The next deadline was June 2015, which required all manufacturers and distributors to begin using the updated label and SDS format. The final deadline is coming up on June 1st 2016.
This final deadline requires implementation of workplace labeling and provide additional training for newly identified hazards. The new Hazard Communication(HazCom12) program requires the use of an updated labeling system that includes: name, address and telephone, product identifier, signal word, hazard statement, precautionary statement, pictograms. For a full explanation of the label requirements please see the following links: www.osha.gov/Publications/OSHA3636.pdf and www.osha.gov/Publications/HazComm_QuickCard_Pictogram.html
Now let’s look what this actually means to employers. It is an employer’s responsibility to ensure that all hazardous chemicals are clearly labeled following the new standard format. All hazardous chemicals shipped after June 2015 should have the new format of labeling and be shipped with the new SDS sheets. If the material in question remains in the manufacture’s packaging, and the label remains clearly visible, then no further labeling is required. Labeling is required if the product is repackaged by the end user. If the hazardous chemicals are purchased in bulk and repackaged for use and storage, then the employer must relabel that container in compliance with HazCom12 standards. One exemption to labeling is, if the hazardous chemical is poured into a smaller container to be used immediately by a worker that keeps procession of the product, then no label is required.
Be sure that your Hazard Communication program is up to date and all employees have been trained. Update your MSDS book with the new SDS sheets as new shipments are received. If there are any questions, feel free to contact the association for assistance. Link to OSHA Small Entity Compliance Guide www.osha.gov/Publications/OSHA3695.pdf