Workers should understand hazardous materials guidelines

In an industrial setting, it's common that hazard communication standards are followed.

You've likely seen one without realizing it. Consider even the warning label on a bottle of bleach in a janitor's closet.

Workplaces with greater potential hazards use these standards more. And now, updates to those longstanding policies could require an overhaul for industries that rely heavily on processing or testing chemicals or that previously were not compliant with the Occupational Safety and Health Administration's (OSHA) hazardous communications standards.

Effective July 19, OSHA standards will reflect the revised United Nations labeling standard. Modifications include:

• Revised criteria for classification of certain health and physical hazards. We will see a change in standards used to classify health and physical hazards and mixtures.
• Revised provisions for updating labels. Chemical manufacturers and importers must provide a label that includes a unified word, pictogram and hazard statement for each category.
• New labeling provisions for small containers. Containers of less than 100 milliliters have new labeling exemptions, requiring immediate outer packing labels and storage requirements.
• Technical amendments related to the contents of safety data sheets. All data sheets will continue to follow the specific, 16-section format.
• Revisions to definitions of terms. Definition changes to A, B, C, and D Appendices and SDS template statements to reflect the revised GHS health hazard definitions, hazard categories and toxicity categories.
• Workplace training. Employers shall train employees regarding the new label elements and safety data sheets format and provide any additional employee training for newly identified physical or health hazards at the time of their initial assignment, and whenever a new chemical hazard the employees may not have previously been trained about is introduced into their work area.
• Trade Secrets. Chemical manufacturers, importers, or employers may withhold specific chemical identity or concentration range from Section 3 of the Safety Data Sheet (SDS) if a trade secret claim is supported, hazardous information is disclosed, and the SDS indicates the withheld information is a trade secret.

Changes affect establishments in a variety of different industries in which workers are exposed to hazardous chemicals or in which hazardous chemicals are produced. The changes to the standard do not change the list of affected industries or establishments. However, some changes specifically affect certain establishment groupings that manufacture aerosols, desensitized explosives, and flammable gases. Other changes affect certain users or manufacturers of hazardous chemicals that are packaged in small containers and manufacturers of chemicals that are not immediately distributed after being released for shipment. However, even if your industry is not affected, anytime there is a policy change such as this, it's a great opportunity for employers to review their protocol and make sure it is up to date. There are a few ways to ensure your hazard communication system is effectively reaching your employees. The steps below are industry best practices:

1. Assign a company delegate to understand the required standard and identify the staff responsible for it.
2. Write and put into place a hazard communication program that details how these issues will be addressed in your workplace.
3. Ensure proper labeling procedures are followed for containers.
4. Keep updated Safety Data Sheets available in the workplace for each on-site hazardous chemical. They should be accessible to employees during their shifts and to medical personnel during an emergency.
5. Maintain a list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate SDS (the list may be compiled for the workplace as a whole or for individual work areas) to ensure an accurate list of chemicals.
6. Conduct employee training. Train employees any time a chemical is introduced into their work area. They should be aware of protective measures and how to implement them.
7. Reassess your hazard communication program to make sure it is still accomplishing your goals.

Fehr Graham is available to help establish or reassess a hazardous communication program for companies as part of our commitment to meeting OSHA safety standards. Please reach out with any questions or for help with your hazardous communication system.