Are You Ready for OSHA’s Updated Right to Know Law?
Next compliance deadline Dec. 1
By Milton Jacobs
In 2012, the Occupational Safety and Health Administration (OSHA) updated its 1994 Hazard Communication Standard, also known as Right to Know, to align it with the United Nations Globally Harmonized System (GHS) of labeling and classification of chemicals.
The update is designed to make labels more reader friendly; standardizes safety data sheets (formerly called material safety data sheets); and requires manufacturers to classify health and physical hazards so that all member United Nation countries (includes some 56 countries in the European Union, Canada, the United States, and parts of Asia) are using the same safety data sheet format.
This law covers both the construction and general industry sectors and requires manufacturers and importers of hazardous chemicals to classify physical and toxicity hazards on chemicals they produce or import. Some key components and compliance dates for the GHS are as follows:
- Provides standardized safety data sheets using a 16-section format
- Modifies current labeling to now include a pictogram, signal word, and precautionary statements.
- Requires manufacturers and importers to give specific information on safety data sheets
- December 1, 2013: Employers are required to train their workers on labeling, pictograms, and the new safety data sheets.
- June 1, 2015: Manufacturers and importers are required to be in full compliance with GHS.
- December 1, 2015: Distributors of chemicals are required to label all containers being shipped with the new GHS labeling format.
- June 1, 2016: Employers are required to update hazard communication programs and labeling and provide additional training to employees for any new hazards uncovered.
Tips for Preparing for the New Requirement
- Review your current hazard communication program. Ensure that you add (in addition to the current, unchanged requirements) the new labeling format, a new training agenda, information on communication of new hazards identified, and your safety data sheet process.
- Review your chemical inventory. Ensure that you have identified all hazardous chemicals.
- Ensure that you have safety data sheets for all of the hazardous chemicals identified in your inventory. If you do not have a safety data sheet contact the manufacturer to request one, keeping in mind that the new data sheets are not technically due out until 2015.
- Educate all of your employees and management. Educate your team on the difference between the labeling systems and the new safety data sheets. Click here for an OSHA quick card on the differences between the old and the new GHS labels.
Milton Jacobs is a Certified Safety Professional with Safety Solution Consultants, Inc. Contact him at firstname.lastname@example.org.
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