OSHA Adopts GHS Affecting MSDS
OSHA has adopted GHS, the Globally Harmonized System of Classification and Labeling of Chemicals. On March 20, 2012, OSHA Director Dr. David Michaels announced the revision to the Hazard Communication Standard (HCS), labeled as ‘HazCom 2012’. He explained the intent of the HazCom 2012 is that employees not only have the “Right to Know” what chemical hazards they were exposed to, but also have now the “Right to Understand.”
According to OSHA HazCom 2012 is expected to affect all U.S. workplaces with exposure to hazardous chemicals, an estimated 5 million facilities with over 40 million workers.
Impact on Classification
MSDS, soon to be simply known as safety data sheets (SDS), will extensively change, as all products will need to be re-classified for health, environmental, and physical hazards based on GHS criteria (see our article “Impact Of GHS On Chemical Classification”). For the first time, safety data sheets will be required to list the CAS number of the hazardous components. Hazardous impurities must also be disclosed.
The first step towards transitioning to GHS is employee training. By December 2013, OSHA will require that employees be trained on the new label elements and safety data sheet format. This will allow employees to see the new labels and SDS’s in their workplaces and understand their use. Full compliance with this rule is expected by 2015.
Once training is in compliance, three additional areas for change are targeted affecting hazard classification, labels, and Safety Data Sheets. Related compliance dates for these changes are to take effect in 2015 and 2016:
- June 1, 2015
Chemical manufacturers and distributors must complete chemical hazard re-classification and apply GHS styled labels and safety data sheets.
- December 1, 2015
Distributors must comply fully with HCS requirements providing a 6-month grace period for shipments of old inventory after the June 2015 date.
- June 1, 2016
Employers must be in full compliance with revised HCS.
For additional information, please take a look at the “A Guide to The Globally Harmonized System of Classification and Labeling of Chemicals (GHS)” from OSHA. The guide’s FAQ discusses background, differences between MSDS’s and SDS’s, application and impact of GHS compared to existing regulations, new definitions of classification hazards, labeling requirements and examples, OSHA expectations on addressing GHS training, and much more.