In the United States of America, GHS is changing only a few things on how we look at chemicals and Chemical Safety. The new HCS still requires chemical manufacturers and importers to classify the chemicals they produce or import and provide hazard information to employers and workers by putting labels on containers and preparing Safety Data Sheets or SDSs (formerly known as Material Safety Data Sheets or MSDSs).

However, the old standard allowed chemical

manufacturers and importers to convey hazard information on labels and

Material Safety Data Sheets in whatever format they chose. The modified

standard provides a single set of harmonized criteria for classifying

chemicals according to their health and physical hazards, and specifies

hazard communication elements.

Major Changes

Definitions: In order to be consistent with GHS, the majority of existing

definitions were modified and/or deleted and replaced with new definitions.

Classification: Chemical manufacturers and importers are required to

determine the hazards of the chemicals they produce or import. Hazard

classification under the new, updated standard provides specific criteria to

address health and physical hazards, as well as classification of chemical

mixtures.

Written Program: OSHA is maintaining the provisions of this section with no

significant changes. GHS does not include any requirements regarding a

written program. However, existing written programs will need to be

modified to reflect new terminology (like SDSs), definition changes and

labeling.

Labels: Chemical manufacturers and importers must provide a label that

includes a signal word, pictogram, hazard statement, product identifier,

supplier identification and precautionary statement for each hazard class

and category.

Safety Data Sheets: The new format requires 16 specific sections to ensure

consistent presentation of important protection information.

Information and Training: To facilitate understanding of the new system, the

new standard requires that workers be trained by December 1, 2013, on the

new label elements and SDS format, in addition to the current training

requirements.

Benefits of the New Standard

The new standard covers over 43 million workers who produce or handle

hazardous chemicals in more than five million workplaces across the

country. The modification is expected to prevent more than 500 workplace

injuries and illnesses and 43 fatalities. Once fully implemented, the standard

will also:

Improve the quality and consistency of hazard information in the workplace,

making it safer for workers to do their jobs and easier for employers to stay

competitive.

Enhance worker comprehension of hazards, especially for low and limited-

literacy workers, reduce confusion in the workplace, facilitate safety training

and result in safer handling and use of chemicals.

Provide workers quicker and more efficient access to information on the

SDSs.

Result in cost savings to American businesses of more than $500 million in

productivity improvements, fewer SDS and label updates and simpler new

hazard communication training.

Reduce trade barriers by harmonizing with systems around the world.

What You Need to Do and When

Chemical Producers (Category 1):

Review hazard information for all chemicals produced or imported, classify

chemicals according to the new classification criteria and update labels and

SDSs by June 1, 2015.

Chemical Users (Category 2): Continue to update SDSs when new ones

become available, provide training on the new label SDS elements by

December 1, 2013, update hazard communication programs if new hazards

are identified and update workplace labels to new GHS criteria by June 1,

2016.

Labels & Programs

OSHA has updated the requirements for labeling of hazardous chemicals

under its HCS.

As of June 1, 2015, all labels from manufacturers will be required to meet the

GHS label format. This will mostly apply to chemical manufacturers.

Workplace labels meeting GHS criteria must be in place as of June 1, 2016.

What does the new GHS label look like and require?

It will require 6 items: product identifier, supplier identification,

precautionary statement, pictogram, hazard statement and signal word.

Employers will simply transfer this information to workplace labeling.

OSHA will continue to allow employers to use other workplace labeling

systems, but the information supplied on these labels must be consistent

with the revised labeling of the GHS system, resulting in a hybrid label of

both systems. This will require a very strong understanding of the

classification system of the GHS system. Both the NFR and HMIG use

numerical rating scales of 0 to 4 (0 being no hazard and 4 being the worst).

GHS hazard categories are just the opposite. Without a firm understanding of

GHS classification, this may introduce further inconsistency of label types if

not done right.

Label Programs

As of June 1, 2015 the HCS will require chemical manufacturers to use

pictograms on labels to alert users of the chemical hazards to which they

may be exposed. Each pictogram consists of a symbol on a white

background framed within a red border and represents a distinct hazard(s).

The pictogram on the label is determined by the chemical hazard

classification.

Health Hazard

Carcinogen

Mutagenicity

Reproductive Toxicity

Respiratory Sensitizer

Target Organ Toxicity

Aspiration Toxicity

Flame

Flammables

Pyrophorics

Self-Heating

Emits Flammable Gas

Self-Reactives

Organic Peroxides

Exclamation Mark

Irritant (skin and eye)

Skin Sensitizer

Acute Toxicity

Narcotic Effects

Respiratory Tract Irritant

Hazardous to Ozone Layer

(Non-Mandatory)

Gas Cylinder

Gases Under

Pressure

Corrosion

Skin Corrosion/Burns

Eye Damage

Corrosive to Metals

Exploding Bomb

Explosives

Self-Reactives

Organic Peroxides

Flame Over Circle

Oxidizers

Environment

(non-Mandatory)

Aquatic Toxicity

Skull and Crossbones

Acute Toxicity

(fatal or toxic)

Safety Data Sheets

The HCS requires chemical manufacturers, distributors or importers to

provide SDSs to communicate the hazards of hazardous chemical products.

As of June 1, 2015, the GHS will require new SDSs to be in a uniform format,

including the section numbers, headings and associated information.

Sections include:

1. Identification includes product identifier; manufacturer or distributor

name, address, phone number; emergency phone number;

recommended use; restrictions on use.

2. Hazard(s) Identification includes all hazards regarding the chemical;

required label elements.

3. Composition/Information on Ingredients includes information on

chemical ingredients; trade secret claims.

4. First-Aid Measures include important symptoms/effects,acute, delayed;

required treatment.

5. Fire-Fighting Measures list suitable extinguishing techniques,

equipment; chemical hazards from fire.

6. Accidental Release Measures list emergency procedures; protective

equipment; proper methods of containment and cleanup.

7. Handling and Storage list precautions for safe handling and storage,

including incompatibilities.

8. Exposure Controls/Personal Protection list OSHA’s Permissible

Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate

engineering controls; personal protective equipment (PPE).

9. Physical and Chemical Properties list the chemical’s characteristics.

Stability and Reactivity list chemical stability and possibility of

hazardous reactions.

10. Toxicological Information includes routes of exposure; related

symptoms, acute and chronic effects; numerical measures of toxicity.

11. Ecological Information* provides information to evaluate the

environmental impact of the chemical(s) if it were released to the

environment.

12. Disposal Considerations* provide guidance on proper disposal

practices, recycling or reclamation of the chemical(s) or its container

and safe handling practices. Will most likely refer reader to section 8

to minimize exposure.

13. Transport Information* provides guidance on classification

information for shipping and transporting of hazardous chemical(s) by

road, air, rail or sea.

14. Regulatory Information* identifies the safety, health and

environmental regulations specific for the product that is not indicated

anywhere else on the SDS.

15. Other Information includes the date of preparation or last

revision.

*Note: Since other Agencies regulate this information, OSHA will not be

enforcing sections 12 through 15 (29 CFR 1910.1200(g)(2)). This information

must be provided to meet GHS requirements for SDSs.

Other OSHA Rules Affected

Flammable and Combustible Liquids 29 CFR 1910.106

This will amend flammable and combustible liquids to conform to new

flammability classes based on new flashpoint methods and boiling points

consistent with the GHS criteria. The biggest change will be the

classification of flammable and combustible liquids. The term “combustible”

will be eliminated and replaced with just “flammable”. The new GHS

definition of flammable aerosols should also be incorporated into this

standard and updated with the acceptable methods for determining

flashpoints.

Process Safety Management (PSM) 29 CFR 1910.119 and Hazwoper 29 CFR

1910.120

Incorporate new flammable liquid classes for consistency.

Welding 29 CFR 1910.252

Incorporate new label format on welding consumables for consistency.

Substance-Specific Health Standards 29 CFR 1910.1001– 1910.1450

(Asbestos, Lead, Cadmium, etc.) Most of the changes made are editorial to

be consistent with new labeling and SDS terminology. The wording on the

signage required in these standards, particularly cancer-causing chemicals

(which almost all of these are), will be modified to reflect standardized

wording required under the GHS criteria.

One of the most significant changes in the revised standard is the adoption

of the United Nations' Globally Harmonized System of Classification and

Labeling of Chemicals (GHS). This adoption provides a single set of

harmonized criteria for classifying chemicals according to their health and

physical hazards. The information required on the Safety Data Sheet (SDS),

formerly referred to as a Material Safety Data Sheet (MSDS), has remained

essentially the same. However, the revision requires the information on the

SDS be presented using 16 specific headings in a specified sequence. 29 CFR

1910.1200(g) provides the heading information to be included and the order

in which they are to be provided. 29 CFR 1910.1200 Appendix D provides the

information to be included under each heading. The SDS format is the same

as the American National Standards Institute Z400.1/Z129.1-2010 Hazardous

Workplace Chemicals – Hazard Evaluation and Safety Data Sheet and

Precautionary Labeling Preparation Standard format that is widely used in

the U.S. and is already familiar to many.

Sections 1 through 8 of the SDS contain general information about the

chemical, identification, hazards, composition, safe handling practices and

emergency control measures. Sections 9 through 11 and 16 contain other

technical and scientific information, such as physical and chemical

properties, stability and reactivity information, toxicological information,

exposure control information and other information including the date of

preparation or last revision. To be consistent with GHS, the SDS must also

contain Sections 12 through 15: ecological information, disposal

considerations, transport information and other regulatory information. OSHA

does not enforce the content of these sections because they fall outside of

its jurisdiction. A description of all 16 sections of the SDS, along with their

contents, is given below:

Section 1: Identification

Identifies the chemical and the recommended uses. It also provides the

supplier’s essential contact information. Required information consists of:

• Product identifier used on the label and any other common names or

synonyms by which the substance is known

• Name, address, phone number of the manufacturer, importer or other

responsible party, and emergency phone number

• Recommended use of the chemical; a brief description of what it

actually does and any restrictions on use

Section 2: Hazard(s) Identification

Identifies the hazards of the chemical and the appropriate warning

information associated with those hazards. Required information consists of:

• Hazard classification of the chemical

• Signal word

• Hazard statement(s)

• Pictograms

• Precautionary statement(s)

• Description of any hazards not otherwise classified

• For a mixture that contains an ingredient(s) with unknown toxicity, a

statement describing how much (percentage) of the mixture consists

of ingredient(s) with unknown acute toxicity. This is a total

percentage of the mixture and not tied to the individual ingredient(s).

Section 3: Composition/Information on Ingredients

Identifies the ingredient(s) contained in the product, including impurities and

stabilizing additives. This section includes information on substances,

mixtures and all chemicals where a trade secret is claimed. Required

information consists of:

• Substances

o Chemical name

o Common name and synonyms

o Chemical Abstracts Service (CAS) number and other unique

identifiers

o Impurities and stabilizing additives, which are themselves

classified and contribute to the classification of the chemical

• Mixtures

o Same information required for substances

o The chemical name and exact percentage of all ingredients

that are classified as health hazards and are:

� Present above their cut-off/concentration limits or

� Present a health risk below the cut-off/concentration

limits

� The exact percentages of each ingredient must be

specified except concentration ranges may be used

in the following situations:

• - A trade secret claim is made

• - There is batch-to-batch variation

• - The SDS is used for a group of substantially

similar mixtures

• Chemicals where a trade secret is claimed

o A statement that the specific chemical identity and/or exact

percentage (concentration) of composition has been withheld

as a trade secret is required

Section 4: First Aid Measures

Describes the initial care that should be given by responders to an individual

who has been exposed to the chemical. Required information consists of:

• Necessary first aid instructions relevant to the route(s) of exposure:

inhalation, skin and eye contact, and ingestion

• Description of the most important symptoms or effects, and any

symptoms that are acute or delayed

• Recommendations for immediate medical care and special treatment

needed, when necessary

Section 5: Fire-Fighting Measures

Provides recommendations for fighting a fire caused by the chemical.

Required information consists of:

• Recommendations of suitable extinguishing equipment

• Information about extinguishing equipment that is not appropriate for a

particular situation

• Advice on specific hazards that develop from the chemical during the

fire; any hazardous combustion products created when the chemical

burns

• Recommendations on special protective equipment or precautions for

firefighters

Section 6: Accidental Release Measures

Provides recommendations on the appropriate response to spills, leaks or

releases, including containment and cleanup practices to prevent or

minimize exposure to people, properties or the environment. It may also

include recommendations distinguishing between responses for large and

small spills where the spill volume has a significant impact on the hazard.

Required information may consist of recommendations for:

• Use of precautions and protective equipment to prevent the

contamination of skin, eyes and clothing

• Emergency procedures, including instructions for evacuations,

consulting experts when needed, and appropriate protective clothing

• Methods and materials used for containment

• Cleanup procedures/techniques

Section 7: Handling and Storage

Provides guidance on the safe handling practices and conditions for safe

storage of chemicals. Required information consists of:

• Precautions for safe handling, including recommendations for handling

incompatible chemicals, minimizing the release of the chemical into

the environment and providing advice on general hygiene practices

• Recommendations on the conditions for safe storage, including any

incompatibilities

Section 8: Exposure Controls/Personal Protection

Indicates the exposure limits, engineering controls and personal protective

measures that can be used to minimize worker exposure. Required

information consists of:

• OSHA Permissible Exposure Limits (PELs), American Conference of

Governmental Industrial Hygienists (ACGIH) Threshold Limit Values

(TLVs) and any other exposure limit used or recommended by the

chemical manufacturer, importer or employer preparing the safety

data sheet, where available

• Appropriate engineering controls

• Recommendations for personal protective measures to prevent illness

or injury from exposure to chemicals, such as personal protective

equipment (PPE) and any special requirements for the PPE

Section 9: Physical and Chemical Properties

Identifies physical and chemical properties associated with the substance or

mixture. Minimum required information consists of:

• Appearance (physical state, color, etc.)

• Upper/lower flammability or explosive limits

• Odor

• Vapor pressure

• Odor threshold

• Vapor density

• pH

• Relative density

• Melting point/freezing point

• Solubility(ies)

• Initial boiling point and boiling range

• Partition coefficient: n-octanol/water

• Flash point

• Auto-ignition temperature

• Evaporation rate

• Decomposition temperature

• Flammability (solid, gas)

• Viscosity

Every item listed above may not be relevant or available. When this occurs, a

notation to that effect must be made for that chemical property.

Manufacturers may also add other relevant properties.

Section 10: Stability and Reactivity

Describes the reactivity hazards of the chemical and the chemical stability

information. Required information consists of:

• Reactivity

o Description of the specific test data for the chemical(s). This

data can be for a class or family of the chemical if such data

adequately represent the anticipated hazard of the

chemical(s), where available.

• Chemical stability

o Indication of whether the chemical is stable or unstable

under normal ambient temperature and conditions while in

storage and being handled

o Description of any stabilizers that may be needed to maintain

chemical stability

o Indication of any safety issues that may arise should the

product change in physical appearance

• Other

o Indication of the possibility of hazardous reactions, including

a statement as to whether the chemical will react or

polymerize, which could release excess pressure or heat, or

create other hazardous conditions

o Description of the conditions under which hazardous

reactions may occur

o List of all conditions that should be avoided

o List of all classes of incompatible materials with which the

chemical could react to produce a hazardous situation

o List of any known or anticipated hazardous decomposition

products that could be produced because of use, storage or

heating

Section 11: Toxicological Information

Identifies toxicological and health effects information or indicates that such

data are not available. Required information consists of:

• Information on the likely routes of exposure: inhalation, ingestion

and/or skin and eye contact

o The SDS should indicate if the information is unknown

• Description of the delayed, immediate or chronic effects from short-

and long-term exposure

• The numerical measures of toxicity

• Description of the symptoms

o This description includes the symptoms associated with

exposure from the lowest to the most severe exposure

• Indication of whether the chemical is listed in the National Toxicology

Program (NTP) Report on Carcinogens or has been found to be a

potential carcinogen in the International Agency for Research on

Cancer (IARC) Monographs or found to be a potential carcinogen by

OSHA

Section 12: Ecological Information (non-mandatory)

Provides information to evaluate the environmental impact of the chemical(s)

if it were released to the environment. The information may include:

• Data from toxicity tests performed on aquatic and/or terrestrial

organisms, where available

• Whether there is a potential for the chemical to persist and degrade in

the environment either through biodegradation or other processes,

such as oxidation or hydrolysis

• Results of tests of bioaccumulation potential, making reference to the

octanol-water partition coefficient and the bioconcentration factor

where available

• The potential for a substance to move from the soil to the groundwater

• Other adverse effects: environmental fate, ozone layer depletion

potential, photochemical ozone creation potential, endocrine

disrupting potential and/or global warming potential

Section 13: Disposal Considerations (non-mandatory)

Provides guidance on proper disposal practices, recycling or reclamation of

the chemical(s) or its container, and safe handling practices. To minimize

exposure, this section should also refer the reader to Section 8 (Exposure

Controls/Personal Protection) of the SDS. The information may include:

• Description of appropriate disposal containers to use

• Recommendations of appropriate disposal methods to employ

• Description of the physical and chemical properties that may affect

disposal activities

• Language discouraging sewage disposal

• Any special precautions for landfills or incineration activities

Section 14: Transport Information (non-mandatory)

Provides guidance on classification information for shipping and transporting

of hazardous chemical(s) by road, air, rail or sea. The information may

include:

• UN number

• UN proper shipping name

• Transport hazard class(es)

• Packing group number, if applicable, based on the degree of hazard

• Environmental hazards

• Guidance on transport in bulk

• Any special precautions an employee should be aware of or needs to

comply with, in connection with transport or conveyance either

within or outside their premises

Section 15: Regulatory Information (non-mandatory)

Identifies any national and/or regional safety, health and environmental

regulations specific for the product that are not indicated anywhere else on

the SDS.

Section 16: Other Information

Indicates when the SDS was prepared or when the last known revision was

made. The SDS may also state where the changes have been made to the

previous version. Other useful information also may be included here.

SDSs are the backbone of the Hazard Communication Standard. They provide

comprehensive and specific chemical information used not only by

workplaces that manufacture, use, transport or store hazardous chemicals,

but also by emergency responders, poison control centers and transporters

of dangerous goods. The revised Hazard Communication Standard provides a

single set of harmonized criteria for classifying chemicals and also stipulates

specific hazard communication elements for SDS labeling, all in an effort to

help improve the safety and health protections for America’s workers.

Q: What are the major changes to the revised Hazard Communication

Standard?

A: The three major areas of change in the revised Hazard Communication

Standard are in hazard classification, labels and safety data sheets.

• Hazard classification: The definitions of hazard 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.

• Labels: Chemical manufacturers and importers will be required to

provide a shipped to container label that includes a harmonized

signal word, pictogram and hazard statement for each hazard class

and category. Precautionary statements must also be provided.

• Safety Data Sheets: Will now have a specified 16-section format.

Q: The United Nations revises the Globally Harmonized System of

Classification and Labeling of Chemicals (GHS) every two years. How will

OSHA communicate changes to the Hazard Communication Standard going

forward?

A: OSHA anticipates that future updates of the Hazard Communication

Standard (HCS) may be necessary and can be done through various

rulemaking options, including:

• Technical updates for minor terminology changes

• Direct Final Rules for text clarification

• Notice and Comment rulemaking for more substantive or controversial

updates such as additional criteria or changes in health or safety

hazard classes or categories

Q: What is the phase-in period for the revised Hazard Communication

Standard?

A: The table below summarizes the phase-in dates required under the revised

Hazard Communication Standard (HCS):

Effective

Completion

Date

Requirement(s)

Responsible Party(ies)

December 1,

2013

Train employees on the new

label elements and SDS

format.

Employers

June 1, 2015

December 1,

2015

Comply with all modified

provisions of the final rule,

except:

Distributors may ship

products labeled by

manufacturers under the old

system until December 1,

2015.

Chemical manufacturers,

importers, distributors and

employers

June 1, 2016

Update alternative

workplace labeling and

hazard communication

program as necessary, and

provide additional employee

training for new identified

physical or health hazards.

Employers

Transition

Period

Comply with either the

revised final standard, the

current standard, or both.

All chemical

manufacturers, importers,

distributors and employers

Q: When must the Safety Data Sheets be updated?

A: If the preparer of an SDS becomes aware of any significant new

information regarding the hazards of the chemical, or ways to protect against

the hazards, than this new information must be added to the SDS within

three months.

The parts of the HCS not related to the GHS–basic framework, scope and

exemptions–have remained largely unchanged.

The Standard comprises six major categories: Hazard Determination, Safety

Data Sheets, Labels and other Forms of Warning, Employee Information and

Training, The Written Hazard Communication Program and Trade Secrets.

The first category, Hazard Determination (29 CFR 1910.1200 (d)) requires

employers to identify and evaluate all chemicals used in the workplace. This

evaluation is based on two hazard categories: listed and defined.

Listed hazards are those included in one of the following references: OSHA

29 CFR 1910.1000 Z tables; American Conference of Governmental Industrial

Hygienists (ACGIH) Threshold Limit Values (TLV); the National Toxicology

Program; or the International Agency for Research on Cancer.

Defined hazards are specified by OSHA as physical or health hazards, such

as combustible liquids, oxidizers, corrosives, reproductive toxins and non-

toxins.

Chemicals exempt from the standard include: wood and wood products

(except wood dust), regulated hazardous waste, tobacco products, food,

drugs, cosmetics, alcoholic beverages, agricultural or vegetable seed treated

with pesticides, various types of pesticides, nuisance particulate, and

articles. These are exempt because they are all regulated by separate

government agencies.

The second major category of the Standard is SDS (29 CFR 1910.1200(g)).

Once you have evaluated and identified all of the hazardous chemicals in

your workplace, you must document them and obtain an SDS for each item.

SDS are available from the chemical supplier or manufacturer. These SDS'

contain specific chemical hazard information such as: physical hazards,

health hazards, routes of entry, exposure limits (if any), precautions for safe

handling and use (if known), spill clean-up procedures, personal protective

equipment to be used, emergency and first-aid procedures, and the name,

address and telephone number of the chemical manufacturer. All of the

information on the SDS must be in English and be available to employees

working with or near the hazardous chemical.

The third category, Labels and other Forms of Warning (29 CFR 1910.1200(f)),

requires labels on all chemicals in the workplace. The label should contain

the identity of the material, appropriate hazard warnings and the name and

address of the manufacturer, importer or other responsible party. Other

appropriate warning information (such as pictures and symbols) may be used

in conjunction with the hazard information. Labels must be legible and in

English. Labels in a second language may be added as long as the English

label is present. For more information on labeling, please refer to Quick Tips

#198, "HazCom and Comparing Chemical Labeling Requirements."

The fourth category, Employee Information and Training (29 CFR

1910.1200(h)), requires employers to provide employees with effective

information and training on hazardous chemicals in their work area at the

time of their initial assignment and whenever a new physical or health

hazard is introduced into the area. The training shall include: methods and

observations used to detect the presence or release of the chemical,

physical and health hazards, protective measures, labeling and explanation

of the SDS.

The fifth category is the Written Hazard Communication Program (29 CFR

1910.1200(e)). It requires employers to fully document the actions taken to

comply with all of the provision of the Standard and to list the responsible

person(s) for each area of the program. A copy of the written program must

be made available, upon request, to all employees and OSHA officials.

The sixth and final category of Hazard Communication involves manufacturer

Trade Secrets (29 CFR 1910.1200(i)). The chemical manufacturer may

withhold the chemical identity, including the chemical name and other

specific information, from the SDS. However, under special conditions, this

secret information may be obtained by health care professionals.

There have been some minor terminology modifications to align the revised

HCS language with that used in the GHS. For example, the term "hazard

determination" has been changed to "hazard classification" and "material

safety data sheet" (MSDS) has changed to "safety data sheet" (SDS).

Major Changes

The three major areas of change are hazard classification, labels and safety

data sheets.

The definitions of hazard have been changed to provide specific criteria for

classification of health and physical hazards and for the classification of

mixtures. These will help ensure that evaluations of hazardous effects are

consistent across the board and labels and safety data sheets are therefore

more accurate.

Chemical manufacturers and importers will be required to provide a

harmonized label that has six standardized elements for classified hazards:

• Product Identifier–Must match product identifier on safety data sheet.

• Manufacturer Contact Information–Including name, phone number, and

address.

• Hazard Pictograms–There are nine pictograms used to convey the

health, physical and environmental hazards. HCS requires eight of

these pictograms, the exception being the environmental pictogram

as environmental hazards are not within OSHA's jurisdiction. These

pictograms will have a black symbol on a white background with a

red diamond frame (see illustrations below):

• Signal Word–Either DANGER or WARNING depending upon hazard

severity.

• Hazard Statements–Standardized sentences that describe the level of

the hazards.

• Precautionary Statements–Steps employees can take to protect

themselves.

OSHA has indicated that it will continue to give employers the flexibility to

determine what types of workplace labels will be required. Employers have

the ability to choose to label workplace containers either with the same

label that the chemical manufacturer or importer used on shipped containers

or with alternate labels that meet the requirements of the standard.

Safety data sheets (SDS) remain the backbone of HCS. With the revision

there is a name and formatting change. The M is dropped from MSDS and

more importantly a standardized 16 section format with a required ordering

of sections is mandatory. This format is essentially the American National

Standard for Hazardous Workplace Chemicals–Hazard Evaluation and Safety

Data Sheet and Precautionary Labeling Preparation, ANSI Z400.1/Z129.1-

2010.

Effective Dates

Employers must train workers on the new label elements and SDS format by

December 1, 2013. Chemical manufacturers, importers, distributors, and

employers must comply with all modified provisions of the final rule by June

1, 2015. However, distributors may ship products labeled by manufacturers

under the old system until December 1, 2015. By June 1, 2016, employers

must update alternative workplace labeling and hazard communication

programs as necessary, and provide additional worker training for new

identified physical and health hazards.

The table below summarizes the phase-in dates required under the revised

Hazard Communication Standard (HCS):

Effective

Completion

Date

Requirement(s)

Who

December 1,

2013

Train employees on the new label

elements and safety data sheet (SDS)

format.

Employers

June 1, 2015∗

December 1,

2015

Compliance with all modified provisions

of this final rule, except: The Distributor

shall not ship containers labeled by the

chemical manufacturer or importer

unless it is a GHS label

Chemical

manufacturers,

importers,

distributors and

employers

June 1, 2016

Update alternative workplace labeling

and hazard communication program as

necessary, and provide additional

employee training for newly identified

physical or health hazards.

Employers

Transition

Period to the

effective

completion

dates noted

above

May comply with either 29 CFR

1910.1200 (the final standard), or the

current standard, or both

Chemical

manufacturers,

importers,

distributors,

and employers

During the transition period, all chemical manufacturers, importers,

distributors, and employers may comply with either the current, revised or

both 29 CFR 1910.1200 standards.

When HCS first took effect in 1985, employees got the right-to-know what

their potential exposure to hazards might be. With this revision, employees

not only know about the potential hazards, they also have a better

understanding of what the warnings mean, what to do if exposed and how to

protect themselves. All employees will be provided with the same

information in the same format.

Q.

Are employers required to maintain two sets of labels and safety data

sheets during the transition period?

A.

No, during the transition period, all chemical manufacturers, importers,

distributors, and employers may comply with either the existing HCS or

the revised HCS, or both. During this time hazard communication

programs may go through a period where labels and safety data sheets

under both standards will be present. OSHA considers this acceptable

and two sets of labels and safety data sheets are not required.

Q.

Why must training be conducted prior to the compliance effective

date?

A.

Many countries are in the process of implementing GHS. Therefore, it is

possible that workplaces may begin to receive GHS compliant labels

and safety data sheets much before December 1, 2015. When

employees begin to see the new labels and safety data sheets, they

must understand the information that is being provided.