OSHA Goes Global

OSHA Aligns with United Nations for Globally Harmonized System of Safety Data Sheets via Hazardous Communication Standard.
The U.S. OSHA has agreed to the United Nation’s standard for Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. This simply means that the material safety data sheet (MSDS) for chemicals will look the same in all nations across the globe. An existing rule called the Hazard Communication Standard was updated to accommodate the global standardization.
The Hazard Communication Standard has always been the rule that requires employers to provide training and chemical hazard information to their employees. The requirement of maintaining an inventory and the material safety data sheets (MSDS) for chemical found in the workplace is the most commonly know portion of the rule. Having a Safety Supervisor, MSDSs, monthly training and a written Hazard Communication Standard is the gist of the rule.
What is new is the format of the MSDS changing to the global standard and becoming known as Safety Data Sheets or SDS which look similar to MSDS and contain the same information but will uniformly convey that information in all languages augmented by the use of universally accepted hazard pictograms.
By December 2013, employers that have chemicals in the workplace must train employees on the updated Hazard Communication Standard.
The Hazard Communication Standard (HCS) is based on a simple concept – that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working.
Identify Responsible Staff by designating a Safety Supervisor. Hazard communication is an ongoing program in the facility. In order to have a successful program, it is necessary to assign responsibility for both the initial and ongoing activities that have to be undertaken to comply with the rule.
The Standard requires a list of hazardous chemicals in the workplace as part of the written hazard communication program. The list will serve as an inventory of everything for which a MSDS/SDS must be maintained. The best way to prepare a comprehensive list is to survey the workplace. Purchasing records may also help. Employers should establish purchasing procedures that result in MSDS/SDSs being received before a material is used in the workplace.
Check your files against the inventory of chemicals in the workplace to ensure that an MSDS/SDS exists for each potentially hazardous chemical. If any are missing, contact the supplier and request one. As chemical manufacturers convert their existing MSDSs to GHS SDS format, GHS labels will accompany these new SDSs.
Begin using the term HAZARD COMMUNICATION STANDARD along with the more familiar MSDS.
All workplaces where employees are exposed to hazardous chemicals must have a written plan which describes how the standard will be implemented in that facility. The plan does not have to be lengthy or complicated. It is intended to be a blueprint for implementation of your program–an assurance that all aspects of the requirements have been addressed. Keep a copy of this written plan in the MSDS binder or readily available in case of an OSHA inspection.
Present the Hazard Communication Standard to employees as this month’s Safety Training topic. Following the presentation, have each employee sign a training log. A sample log can be downloaded at https://ccar-greenlink.org/wp-content/uploads/Employee-Safety-Training-Log1.pdf. Keep the monthly Safety Training Record on file (such as in the RED MSDS binder) in the event of an OSHA inspection.

Get started on a compliant Safety Program with some simple steps:

  1. Use a RED three-ring binder to keep all Safety Training & MSDS/SDSs;

  2. Create a written Hazard Communication Plan using the information in this article;

  3. Keep logs of monthly Safety Training assigned to employees by having monthly safety meetings.

Employee training on Hazard Communication will be a key factor in the success of your organization’s implementation of GHS. The end result will be improved safety for workers via their awareness of the pictograms and other information provided on manufacturers’ GHS SDSs and labels, in particular the necessary steps to protect people and the environment when responding to a chemical hazard.
Monthly Safety Training
Providing training topic each month can be a challenge but should not be used as an excuse to be non-compliant. Encourage those employees using the online safety training program and those that are not such as office personnel to use the on-line program to augment the brief meeting.
Safety training should not have a beginning and an end, but represent an ongoing effort that continually promotes a safe working environment.
The online safety training is based on U.S. Department of Labor, Occupational Safety and Health Administration (OSHA) standards, which require that personnel be trained on safety and environmental regulations at the beginning of their employment, and at least annually thereafter. Completion of the online courses is one great way to meet this requirement with confidence.
OSHA has concluded that effective management of worker safety and health protection is a decisive factor in reducing the extent and the severity of work-related injuries and illnesses. Effective management addresses all work-related hazards, whether or not they are regulated by government standards. .
Sue Schauls is an independent environmental consultant with automotive expertise. She is the Environmental & Safety Consultant for CCAR-GreenLink the EPA automotive compliance assistance center. She is the Executive Director & regulatory consultant for the Iowa Automotive Recyclers (IAR), she developed and implements the Iowa – Certified Auto Recyclers Environmental (I-CARE) Program. She contributes articles to several trade publications and is a member of ARA Technical Advisory and Certified Auto Recyclers Committees.  Sue has a bachelors of Arts degree in Science: Environmental Planning from the University of Northern Iowa, 1996.

Written by CCAR