If you read one article on OSHA compliance of signs and labeling this year then keep reading this one. Misunderstanding the future use of the NFPA diamond could cost your facility thousands.
Currently, workers are trained to identify hazardous materials and procedures in an emergency by the brightly colored quadrants of the diamond. Knowing the required personal protection equipment (PPE) and the severity of the hazardous material’s effect on us is critical when an emergency exposure occurs. The NFPA diamond was originally created in 1957 by the National Fire Prevention Association (NFPA) for emergency responders. The goal was to create a standardized system to train for and provide a quick response in an emergency where hazardous materials are present. Eventually OSHA adopted the NFPA diamond as part of their Right-to-Know (RTK) standard in 1986. The RTK regulations helped standardize OSHA’s requirements for labeling hazardous material in general, for storage or handling purposes.
All of that is about to change—sort of. OSHA is in the process of adopting the Globally Harmonized System's (GHS) labeling guidelines for identifying hazardous material. The alignment with GHS is part of the new Hazard Communication Standard (HCS) effective June 2015, and RTK labels will no longer be required. Instead you must have a HazCom 2012 label. We have been talking about HazCom 2012 for months now in preparation of OSHA’s changing requirements. Research on how the new HCS will impact the NFPA diamond and RTK standard has brought clarity to the easily misunderstood subject. Maybe you've searched Right-to-Know (RTK) before, but now is the time to pay attention to only HazCom 2012—GHS aligned labels, and potentially using NFPA diamond labels as a supplement, before you are fined for a hazard communication violation.
Here is a recap:
The NFPA diamond will still be used for its original purpose: a reference for emergency responders—we definitely don’t want those guys getting confused!
The NFPA diamond label will not be required by OSHA, but you may use it to supplement the new HCS.
The RTK standard, typically used in conjunction with the NFPA diamond, will no longer be the required standard, but again, can be used in supplement to the new HCS.
The new HCS is effective, June 2015.
You can be fined up to $7,000 per violation if your employees are not currently trained on the new HCS, and you can also be fined if you are not using the new HCS labels by the due date.
All the regulation and standard changes bear down to a simple fact. Your employees should fully understand two types of labels in regards to hazardous materials: The NFPA diamond – if you want to help emergency responders do their job and the HazCom 2012 label for OSHA requirements. You can find the most accurate, easy-to-follow NFPA diamond resource for your workers with our NFPA Quick Reference Cards. Your employees will:
Become familiar with chemical names and CAS numbers.
Quickly identify severity and type of hazard potential.
Recognize which PPE is required for the situation.