Getting Started: OSHA’s Revised Hazard Communication Standard

New and emerging standards can be daunting, but smart OEMs are taking the process step by step in order to make headway in addressing the demands from the Occupational Safety and Health Organization (OSHA) hazardous chemical standards.

First, manufacturers need to begin by classifying their products for compliance with the Hazardous Communications Standard (HCS) and Globally Harmonized System for Classification and Labeling of Chemicals (GHS). If dealing with pure substances, this will be an easier task than if classifying mixtures. But either way, the criteria from the GHS are the rule. Classification will take longer than the old methods, and organizations need to begin this process now. The challenge is to work with accurate data. GHS does not require “testing,” but it does require obtaining whatever information is available to accurately assess products.

Some things may calculate out to be more toxic as OSHA has expanded the definition of “toxic” from a toxicity of 500 mg/ kg out to 2,000 mg/kg in order to be consistent with the GHS. On the other hand, removal of the old 1% bright line means that you have 1% or more of a material with a certain health hazard, and mixtures will not automatically inherit that hazard. For example, some things formerly labeled as irritants may no longer be classified as irritants. So the classification and sub-classification, known as “categories,” must be dealt with first.

Next, the GHS criteria will lead to the selection of symbols, signal words such as Danger or Warning, statements of hazard, and statements of precautions. These all have to go into Section 2 of the 16-section format of the Safety Data Sheet.

And following these considerations, here comes an important issue…as label content will appear on the SDS, both the SDS and the label need to be deployed together. SDSs are documents and can be sent out both in paper or as electronic files, but labels need to be applied to the actual package, which is not as easily accomplished. Key challenges of label production that must be accounted for include accommodating for color printing, dealing with different size products, accommodating multiple languages and transactional data.

As the industry is well aware by now, regarding color, OSHA requires a red border on all symbols used to communicate hazard categories. Black will just not do.

For many, using pre-printed label stock with red diamonds has become less practical, as the number of possible variations of pictograms needed varies and also requires manual oversight to make sure the correct label stock is being used.

Package size is also an important consideration in labeling as chemicals can be transported through supply in containers that vary in size from drums to small vials. The label needs to address both OSHA regulations and the size restrictions of the container, so for small packages it is a challenge to effectively utilize the limited real estate on a label.

Then there is the issue of dealing with languages on a label. In the United States, English is mandatory while other languages can be added optionally. For most other countries, e.g. European countries, the label must be produced in that country's language but may also require other languages if you sell and transport in other countries.

Extending the challenge of GHS labeling is a common requirement to apply transactional data such as batch numbers, lot numbers, or packing dates. This data, in conjunction with the variables of color, size and language, introduce complexity on the label that make pre-printing labels impractical.

Real-time, data-driven labeling is one of the primary pathways of dealing with these issues to ensure that the correct symbols, languages, and transactional data appear on labels of any size or shape. This approach also enables manufacturers to leverage the same regulatory content to ensure that the SDS and label agree with each other. The last thing they want is for the SDS to say one thing, and the label to say something else.

Ongoing regulatory changes in the chemical industry, successful GHS compliance, and regional regulatory adherence all require rapid labeling changes to be deployed quickly throughout the organization. The ultimate goal is meeting the requirements presented by the GHS at the same time you deal with the complexity of labeling hazardous materials to protect all participants in the global supply chain. To achieve this goal, companies must first understand the impact and changes that the GHS necessitates while pursuing an approach that accounts for the unprecedented level of complexity and change required for labeling in the chemical industry.

You can hear me talk more about these issues in a recent webinar titled How to Manage Labeling Changes for GHS Compliance.

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