In every workplace—even simple office spaces—there are chemicals used that could have an impact on employee health and well-being. To address this fact and to minimize risks from exposure to chemicals, the Occupational Safety and Health Administration (OSHA) has created requirements that explain what employers must do to ensure employees have information about the chemicals in use in the workplace and how to manage exposure to those chemicals.
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These regulations are commonly referred to as hazard communication (HazCom) requirements. They’re also sometimes called worker “right-to-know” information. In the past, OSHA’s Hazard Communication Standard (HCS) was put in place so employees had information about potentially hazardous chemicals and what types of protective measures were available and necessary when dealing with them. By having standards in place and by requiring employers to have a written HazCom program, employees have access to information about any chemicals they may be exposed to while on the job. Information about the chemicals and the protective measures that are available to mitigate risks can help keep employees safe. HazCom also helps employees know what to do in case of accidental exposure to a toxic substance. Having these standards can reduce the chance of injury and illnesses from such exposures.
OSHA’s HazCom Is Now Aligned with GHS
The United Nations has put forth a globalized system that is designed to bring together hazard communication standards across countries. This is important because before the implementation of this system, different countries had different labeling requirements, icons, and symbols. This created confusion and an increase the risk of injury since so many chemicals are now used and shipped across borders.
The system promoted by the United Nations is called the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). According to information provided by OSHA, “The GHS was negotiated in a multi-year process by hazard communication experts from many different countries, international organizations, and stakeholder groups. It is based on major existing systems around the world, including OSHA’s HCS and the chemical classification and labeling systems of other U.S. agencies.”[i]
It should be noted that GHS is not, however, a regulation. It is meant to be a framework for other organizations (like OSHA) to update their own regulations to be in alignment—and that’s exactly what has happened. In 2012, OSHA revised its HCS to be in alignment with GHS. In practice, there were several major changes required, including the use of updated labeling, the change to safety data sheets (SDSs)—previously known as material safety data sheets, or MSDSs—and new hazard definitions. These changes sound straightforward enough, but they are quite expansive in scope and have been implemented in phases since 2012[ii]. These phases started with the transition to SDSs and training employees on all of the new standards in 2013. Employers then had until mid-2015 to comply with the remaining changes. Additionally, employers have until June 1, 2016, to update all alternative workplace labeling and all other information related to HazCom as needed. During this time, employers are also responsible for ensuring employees are trained on newly identified hazards. (Prior training on all of the new labels and related information was required back in 2013, as noted above.)
Ease of use is paramount to effective standards, and GHS helps ensure this by making standards consistent not only across countries but also across various organizations that are adopting the GHS standards. The switch to GHS means that worker safety is improved through better consistency in labeling standards, and it will help to ensure that labeling is not a barrier to efficient working environment even when dealing with international customers or suppliers.
What has been your organization’s experience with the transition to GHS from the former OSHA HCS regulations? Are you still transitioning? The United Nations will continually update the GHS; as of now, planned changes are to be implemented every 2 years.
*This article does not constitute legal advice. Always consult legal counsel with specific questions.
[i] https://www.osha.gov/dsg/hazcom/hazcom-faq.html
[ii] For more information: https://www.osha.gov/Publications/OSHA3642.pdf
About Bridget Miller:
Bridget Miller is a business consultant with a specialized MBA in International Economics and Management, which provides a unique perspective on business challenges. She’s been working in the corporate world for over 15 years, with experience across multiple diverse departments including HR, sales, marketing, IT, commercial development, and training.