Review: Big Changes in Labeling for OSHA’s Revised Hazard Communication Standard

Last week, we talked about broad realiteis of Occupational Safety and Health Organization (OSHA) hazardous chemical standards. Now, let's look at what is going to be different in OSHA's Hazardous Communications Standard (HCS) and Globally Harmonized System for Classification and Labeling of Chemicals (GHS) compliant labeling.

Some Things Change While Others Don't

Labels will now have more information on them, and will have to be revised to include symbols, standard signal words, and standard phrases. Other text, such as contact phone numbers and statements about ingredients with unknown toxicity will also be required. Because of the regional challenges presented by a widening global supply chain, signal words and phrases must be translated into multiple languages, making labels more efficient instruments for global hazard communication.

And Some Things Are Changing a Lot…

Before 2015, as a performance standard, manufacturers could meet OSHA requirements by methods of their own choosing. Now as a specification standard, manufacturers must follow methods of compliance outlined by OSHA. From 2015 onward, manufacturers will have to examine all available information and make a scientifically based determination where conflicting toxicity information is found. Also, formulators will now have a greater degree of responsibility for determining the correct hazards associated with ingredients supplied by others where the identity of the ingredient is known.

Definitions have expanded, especially for physical hazards. OSHA used to talk about flammability, pressure, explosively, and reactivity. It is now more finely defined by GHS into these categories:

  • Explosives
  • Flammable gases
  • Oxidizing gases
  • Pressurized gases
    • Compressed gases
    • Liquefied gases
    • Refrigerated liquefied gases
    • Dissolved gases
  • Flammable liquids
  • Flammable solids
  • Self-reactive substances
  • Pyrophoric liquids
  • Pyrophoric solids
  • Self-heating substances
  • Water Reactive producing flammable gases
  • Oxidizing liquids
  • Oxidizing solids
  • Organic peroxides
  • Corrosive to metals
  • Explosive dusts

OSHA regulates all these hazards, including some others like “explosive dusts.”

Likewise, health hazards have been more finely defined, but the change is not as dramatic as with physical hazards. The increased number of physical hazards is more in line with worldwide definitions already existing for the transport of dangerous goods. The changes to health hazards had to accommodate the various international systems with the guiding principle that no country would reduce the level of protection that previously existed. This will impact both safety data sheets and labels.

The older definitions of health hazards include:

  • Irritants
  • Corrosives
  • Toxins
  • Sensitizers
  • Effects on target organs (i.e. liver, kidney, nervous system, blood, lungs, mucous membranes, reproductive system, skin, eyes, etc.)

The newer definitions include:

  • Acute toxicity, oral
  • Acute toxicity, dermal
  • Acute toxicity, inhalation
  • Aspiration hazard
  • Skin corrosion / irritation
  • Eye corrosion / irritation
  • Respiratory sensitization
  • Skin sensitization
  • Germ cell mutagenicity
  • Carcinogenicity
  • Reproductive toxicity, fertility
  • Reproductive toxicity, development
  • Specific target organ toxicity (STOT)
    • Single Dose
    • Repeat Dose

Most of these categories had been regulated previously, but now all categories of these hazards are being regulated. It is important to clarify that OSHA will not regulate materials of lower toxicity that would be in the home where children are present; this is because The United States Consumer Product Safety Commission regulates consumer labels, and that organization has yet to propose adoption of the GHS system.

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

Stay tuned for the final installment of this series on GHS labeling.

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