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The written hazard communication program that OSHA requires covered employers to maintain plays a central role in workplace chemical safety. It outlines practical measures the site will take to comply with Hazard Communication Standard (HCS) requirements for container labeling, safety data sheets, and employee training.

Employers must update the hazcom program to reflect changes on site, such as when a new chemical is introduced or when employees' responsibilities change. Plan updates may also arise from changes initiated by OSHA. After the agency incorporated the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) into the HCS in 2012, workers nationwide who handle and use hazardous chemicals received updated training on multiple topics, including how to recognize and use new hazard labels and the new 16-section SDS.

With OSHA ready to fold elements of the seventh edition of GHS into the HCS, employers should prepare for changes that will affect their written hazcom programs and their approaches to employee training. (For a closer look at changes related to container labels, safety data sheets, employee training, and other topics, read a succinct, point-by-point discussion of OSHA's proposed rule that appeared on SynergistNOW in May 2023.)

Labeling Changes

As part of incorporating the seventh edition of GHS, OSHA will provide flexibility for chemicals shipped in bulk containers and in containers too small for complete labels. In both cases, updated training is vital for employees who receive, handle, or use these containers and rely on clear labeling for potentially life-saving warnings.

OSHA may permit bulk containers to be sent with a physical or electronic shipping paper rather than labels. In some situations, the HCS would allow for reduced information on small containers. Workplaces that currently receive chemicals in small containers should be ready to identify any changes to container labels and prevent those changes from negatively impacting safety.

For employees who see and use the same labels on every shift, a visual aid can be especially helpful. Showing the "old" and "new" labels side by side will help ensure workers know where to find the key pieces of information they expect or may need in an emergency.

Changes to SDS

The addition of new hazard categories and subcategories to the hazcom regulations will require manufacturers to reclassify some types of aerosols, explosives, and gases. This will entail changes or additions throughout the SDS, including classification details, product identifiers, signal words, hazard statements, and pictograms in Section 2 and employee protection measures, release containment, emergency procedures, personal protective equipment, material handling and storage precautions, and more in Sections 4–8.

A change to the way OSHA treats trade secrets could affect what employees see in Section 3. When a manufacturer or importer withholds a chemical's concentration range as a trade secret, OSHA may soon require the use of "prescriptive ranges."

Employees who review a product's SDS for accuracy or safety information should be aware of potential changes to a product's documentation before they cause confusion or misconceptions. By reviewing the workplace hazcom program, employers can get a clear sense of how imminent updates to the HCS will affect their employees. By updating both the plan and employee training in a timely manner, safety leaders can maintain a high level of safety and avoid costly citations for HCS violations, which continue to be among the most violated general industry standards every year.

Resources

Lion News: "What's in a Written Hazard Communication Program?" (November 2022).

SynergistNOW: "OSHA's HazCom Standard and the GHS Seventh Edition" (May 2023).