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HazCom 2012, SDS, and RTK

By Jordy Byrd

Natural Structures is in the business of creating fun. The Baker City, Oregon design and manufacturing company has built custom water slides shaped like alligators and stainless steel slides – including one used inside Google headquarters – since 1976.

Just like the curvature in their slides, Natural Structures’ production was thrown off curve when OSHA announced in 2012 revisions to the Hazard Communication Standard (HCS) (29 CFR 1910.1200). Under the revision, known as HazCom 2012, employers must adhere to elements of an internationally-recognized UN standard called the Globally Harmonized System for the Classification and Labeling of Chemicals (GHS). GHS describes specific tests to categorize hazards posed by a chemical, and assigns label details for each hazard based on test results.

HazCom 2012 also requires chemical manufacturers to send out a 16-section Safety Data Sheet (SDS) – in replace of the MSDS sheet – which provides detailed information regarding chemicals.

“The end of 2012 was kind of the initial, ‘now what’ phase?’” said Justin Emmons, safety coordinator with Natural Structures. “Last year we really started buckling down, getting everyone trained and on the same page.”

Natural Structures is among an estimated 5 million workplaces in the United States affected by HazCom 2012. Emmons and his team of 50 employees represent a pin drop of the approximately 43 million employees exposed to hazardous chemicals in the workplace each day.

The transition has been a laborious project since GHS compliance dates and regulations came into effect May 25, 2012 – but the bottom of the slide is near.

By June 1, 2015 all manufacturers, importers, and employers must comply with new GHS label requirements and SDSs. No new chemicals may be produced or enter the country without proper labels after this point; although distributors were granted an extra six months to deplete through existing inventory until Dec. 1, 2015.

Emmons and his team met the initial Dec. 1, 2013 GHS compliance training deadline wherein employers were required to provide training on new label elements and SDS formats. The transition process has been tedious, but necessary.

“Teenagers think they’re invincible,” Emmons said. “But adults can get into that mindset too with hazardous chemicals.”

Right to Know

Workers have a right to know.

To know whether the gaseous material produced in their day-to-day operations is a carcinogen, or whether a drop of unsuspecting liquid will burn through their flesh. That’s where safety coordinators like Emmons step in.

Emmons coordinates monthly safety meetings, writes training programs, and facilitates new hire safety training. He ensures his fabrication team properly handles studding fluids; that the power coat department correctly uses cleaning solutions, and fiberglass resins are safely handled on job sites.

Like most workers, Emmons wears many hats and is involved in the construction of 20’ stainless steel slides installed across the globe.

That’s where OSHA regulations take over. OSHA originally creating HCS (1910.1200) in 1994 – often called the Right-To-Know standard. HCS 1994 required chemical manufacturers and distributors to evaluate chemical hazards and provide information about health and physical hazards via MSDSs and labels – but didn’t prescribe a format for labeling.

The lack of direction resulted in make-shift labeling and confusion. Natural Structures fell into this grey area.

“The labels were our biggest concern,” Emmons said, regarding new regulations. “Before, if we had a spray bottle filled with something, we just wrote on it with a Sharpie.”

HazCom 2012 created a unified system. OSHA estimates the system will result in the prevention of 43 fatalities and 585 injuries and illnesses annually, and produce $250 million on an annualized basis due to reduced occupational risks.

Eliot Lapidus works to prevent such risks.

Lapidus is a safety and health manager with the Associated General Contractors (AGC) Oregon/Columbia Chapter. His team provides HazCom 2012 training to ensure the approximate 650 construction firms in his chapter have the information they need to use, control, store, and work safely with potentially hazardous materials.

Safety professionals like Lapidus have been flooded with questions surrounding OSHA deadlines – and spreading the word can be an uphill battle.

“The most common question is ‘why?’” Lapidus said. “Why should we bother with this? We kind of had to break the ice with companies because they didn’t understand the importance or consequences of new regulations….Once they hear the whole story it’s easier to swallow.”

These revisions are not without a learning curve. Hazard communication continues to be one of OSHA’s most cited violation. Top sections cited include:

  1. Employee information and training
  2. Developing, implanting, and maintaining a written hazard communication program
  3. Labels on shipped containers
  4. Employee training on new label elements and SDS formats 

Despite the learning curve, Emmons says training updates have already spurred constructive conversations in his facility.

“Guys have been asking me if they need to wear a respirator or gloves when handling certain materials – even asking about wearing extra safety gear,” Emmons says. “The requirements for handling materials haven’t necessarily changed, but it’s opened up a dialog, and workers are more confident about what they’re working with.”

Label Requirements

Labels have become comprehensive. Workers will soon know within a glance not only if a chemical is hazardous, but how hazardous it is based upon classification standards, how to handle it, protect themselves, and provide proper incident response.

HazCom 2012 now requires the following elements on labels:

  • Name, Address, and telephone number of the chemical manufacturer, importer or other responsible party.
  • Product Identifier outlines how the hazardous chemical is identified. This can be the chemical name, code number, or batch number. The manufacturer, importer, or distributor can decide the appropriate product identifier.
  • Signal Words are used to indicate the level of severity of the hazard and alert the reader to a potential hazard on the label. There are only two words used as signal words, “Danger” and “Warning.” Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. There will only be one signal word on the label no matter how many hazards a chemical may have.
  • Hazard Statements describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. All of the applicable hazard statements must appear on the label.
  • Precautionary Statements describe recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling. There are four types of precautionary statements: prevention (to minimize exposure); response (in case of accidental spillage or exposure emergency response, and first-aid); storage; and disposal.
  • Hazard pictograms are graphic symbols used to communicate specific information about the hazards of a chemical. On hazardous chemicals being shipped or transported from a manufacturer, importer or distributor, the required pictograms consist of a red square frame set at a point with a black hazard symbol on a white background, sufficiently wide to be clearly visible. A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label. While the GHS uses a total of nine pictograms, OSHA will only enforce the use of eight.

Commonly used labels such as the National Fire Protection Association (NFPA Diamond) and Hazardous Materials Identification System (HMIS) may continue to be used in workplaces so long as the information isn’t contradictory to HazCom 2012 labels; however these labels cannot stand alone, as they no longer satisfy OSHA’s labeling requirements.

Natural Structures and other employers are responsible for maintaining these labels on containers, including tanks, totes, and drums, and must re-label the secondary container if the information has been removed or defaced. Emmons purchased a DuraLabel Pro 300 thermal transfer label printer with DuraSuite Labeling Software to get the job done.

“The moment labeling requirements were brought up we started researching printers,” he said. “I wasn’t sure how we were going to get the pictogram and all the descriptions on the labels made. Now we print what we need, when we need it.”

Emmons and his team chose a label maker as opposed to custom labels because last minute jobs inevitable arise. Natural Structures has used the DuraLable Pro 300 to create labels used on everything from reduced containers, to spray bottles filled with cleaning solutions.

“I’ve never set up a thermal printer before but I eventually got it,” Emmons said. The software is pretty easy to work with and when we need to print something we just fire it up.”

GHS Safety Data Sheet

MSDS’s are a thing of the past. Chemical manufacturers, distributors, and importers are now required to provide SDS’s to communicate information on these hazards. The information contained in the SDS is largely the same as the MSDS, except now the SDSs are required to be presented in a consistent user-friendly, 16-section format.

There is a list of required headings, in a required order, and each element is clearly defined. The sections are:

  1. Identification
  2. Hazard(s) Identification
  3. Composition/Information on Ingredients
  4. First-Aid Measures
  5. Fire-Fighting Measures
  6. Accidental Release Measures
  7. Handling and Storage
  8. Exposure Controls/Personal Protection
  9. Physical and Chemical Properties
  10. Stability and Reactivity
  11. Toxicological Information
  12. Ecological Information
  13. Disposal Considerations
  14. Transport Information
  15. Regulatory Information
  16. Other information (such as the date of preparation or last revision)

Sections 12-15 are needed in order to match the international requirements of the GHS system, but fall outside the jurisdiction of OSHA in the United States. As such, OSHA requires that those sections are present, but does not have any requirements as to their content.

Waiting Game

Today Emmons waits.

He and countless other safety coordinators await the arrival of GHS-complaint SDSs from the respective 90,000 hazardous chemical manufactures nationwide. Natural Structures will receive upwards of 300 SDSs in the coming months before the June 1, 2015 deadline.

“We are expected to be flooded with them this year…everything’s got one and they all need copied and filed,” he said.

He uses his DuraLabel Pro 300 printer to prep labels for future use, and trains new employees – people with 30 years on the job, and those straight out of high school – regarding new labeling and SDS requirements. This labor is almost impossible to quantify in dollars.

“We’ve always been concerned about time, worried about man hours taken way from production,” Emmons said.

OSHA estimates the revised Hazard Communications Standard will cost the United States $201 million dollars on an annualized basis. The four major expenditures include:

  • $22.5 million: Classifying chemical hazards in accordance with GHS criteria and revising SDSs and labels to meet new format and content requirements.
  • $95.4 million: Training employees to become familiar with new warning symbols and the revised SDS sheets.
  • $59 million: Allowing management to become familiar with the new GHS system and to engage in other management-related activities as may be necessary for industry's adoption of GHS.
  • $24.1 million: Printing packaging and labels for hazardous chemicals in color.

Companies and safety professionals like Lapidus are still navigating the HazCom 2012 revisions – and know the door is open for more interpretation. The end goal is worth it.

“It’s going to take some time to adjust…” Lapidus said. “But it’s the same battle for all of us. We want to make a safer working environment. Compliance isn’t our number one objective; it’s the genuine safety of the people who are working.”

Emmons says Natural Structures is prepared for the June 1, 2015 compliance deadline. Right now, it’s business as usual crafting curly cue water slides. Despite the initial investment, Emmons says his company has handled the transition in stride.

“You just gotta’ keep a cool head about it,” he said laughing. “The transition has been a little less painful than we anticipated…and most importantly, it’s good for people to be more aware of the chemicals they are using every day.”

A version of this story originally appeared in Occupational Health & Safety Magazine.