The Hazard Communication Standard 2012 is now aligned with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) that provides many benefits, including:
- Providing a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets;
- Improving the quality and consistency of hazard information in the workplace;
- Helping reduce trade barriers;
- Productivity improvements for American businesses that regularly handle, store, and use classified hazardous chemicals;
- Providing cost savings for American businesses that periodically update safety data sheets and labels for classified chemicals.
Historical note: The old HCS 1994 gave workers the right to know, but the HCS 2012 gives workers the right to understand: this is a very important change in OSHA’s approach.
OSHA has defined the term “substances” as chemical elements and their compounds in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurities deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition.
For the purposes of the HCS, a hazardous chemical means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.
Physical hazards – a chemical that is classified as posing one of the following hazardous effects:
- flammable (gases, aerosols, liquids, or solids)
- oxidizer (liquid, solid or gas)
- self-reactive; pyrophoric (liquid or solid)
- organic peroxide
- corrosive to metal
- gas under pressure or
- in contact with water emits flammable gas
Health hazard – a chemical which is classified as posing one of the following hazardous effects:
- acute toxicity (any route of exposure)
- skin corrosion or irritation
- serious eye damage or eye irritation
- respiratory or skin sensitization
- germ cell mutagenicity
- reproductive toxicity
- specific target organ toxicity (single or repeated exposure) or
- aspiration hazard
The criteria for determining whether a chemical is classified as a health hazard are detailed in 1910.1200, Appendix A – Health Hazard Criteria.
HCS 2012 Pictogram Requirements
The HCS 2012 requires GHS 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.
While the GHS uses a total of nine pictograms, OSHA will only enforce the use of eight. The environmental pictogram is not mandatory but may be used to provide additional information. Workers may see the ninth symbol on a label because label preparers may choose to add the environment pictogram as supplementary information.
Under the HCS 2012, labels on containers shipped from manufacturers or distributors must be labeled, tagged or marked with the following six items:
- Product Identifier – This should include the chemical identity of the substance.
- Signal word – Signal words used in GHS are “Danger” and “Warning.” Danger is for the more severe hazard categories.
- Hazard Statements – This is a phrase assigned to a hazard class and category that describes the nature of the hazards of a hazardous product, and the degree of the hazard.
- Pictograms – These include symbols plus other elements, such as a border, background pattern or color that conveys specific information.
- Precautionary statements – These are phrases (and/or pictograms) that describe the recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous product.
- Supplier identification – This contains the name, address, and telephone number of the manufacturer or supplier of the substance or mixture.
The employer must educate and train exposed employees on classified workplace chemicals.
Employees must receive information and training that ensures their awareness of the chemical hazards used in their work area. Employers must provide this information when an employee is initially assigned to a work area where hazardous chemicals are present and before assignments involving new exposure situations.
Employees must be informed of:
- the requirements of the HCS 2012
- any operations in their work area where hazardous chemicals are present
- the location and availability of the written hazard communication program (including the required list(s) of hazardous chemicals and SDSs required by the HCS)
To make sure all training requirements are met, it is recommended to review each section of the SDS. Group discussion and examples can be effective training strategies to make the training more interesting to students. Demonstrating and practicing the use of PPE for properly using and cleaning up spills is especially important.
Employee training must include at least:
- Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area.
- The physical hazard, health hazards, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area.
- The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
- The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.