OSHA Issues Inspection Directive for Revised HazCom Standard
The Occupational Safety and Health Administration (OSHA) published new directions for its inspectors enforcing the agency’s recently revised hazard communication (HazCom) standard.
OSHA revised the standard in March 2012 to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals.
The instructions outline changes to the standard such as the revised classification and standardized labeling of chemicals, and the new format for safety data sheets. The directive also explains how the revised standard is to be enforced during its transition period, and after the standard is fully implemented on June 1, 2016.
The directive explains how the standard interacts with other OSHA requirements and with the U.S. Department of Transportation requirements for the labeling and handling of hazardous substances, and replaces earlier interim enforcement guidance.
Additionally, OSHA inspectors are instructed on the use of safety data sheets to support general-duty clause citations for exposure hazards. Information from the sheets can help determine whether the four required elements for a general duty clause violation are present: the existence of a hazard, employer or industry recognition of the hazard, its likelihood to cause death or serious injury, and feasible means to eliminate or reduce the hazard.
Deadlines
Under the revised standard, employers were required to train workers on the new label elements and safety data sheets by Dec. 1, 2013. Chemical manufacturers, importers and distributors had to comply with revised safety data sheet requirements by June 1, 2015. Manufacturers and importers also had to comply with new labeling provisions by that date. Distributors have until Dec. 1, 2015, to comply with labeling provisions as long as they are not relabeling materials or creating safety data sheets, in which case they must comply with the June 1, 2015, deadline.
Employers must update their written hazard communication program, update any alternative workplace labeling, and provide additional employee training no later than June 1, 2016.