In 2012, the U.S. Occupational Safety and Health Administration (OSHA) updated its Hazard Communication Standard (HCS). The revision sought to make the HCS align more closely with international compliance and provide a more standardized approach to the formatting of OSHA’s material safety data sheets (MSDSs), which will transition to safety data sheets (SDSs). Additionally, the update implemented new labeling requirements. These changes will make the HCS closer to standards of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
OSHA is introducing the update gradually. The implementation period started Dec. 1, 2013 and ends June 1, 2016. Employers must be compliant with the SDSs requirement by June 1, 2015.
What the revised HCS entails
The new provisions pertain to distributors, importers and manufacturers of chemicals. While the goal of the HCS, which is to give end users information about hazardous chemicals in products, remains the same, OSHA revised the standard to make the information more accessible. Per OSHA’s standards, these chemicals are:
- Pyrophoric gases
- Combustible dust
- Simple asphyxiants
- Health or safety hazards for any other reason
Manufacturers, distributors and importers must now communicate these hazards to end users via SDSs, which are largely the same as MSDSs. The key change is the new forms use a 16-section format to make the information easy to digest.
“Employers must be compliant with the SDSs requirement by June 1.”
Overview of the 16 sections
Sections 12 through 15 are the ones that specifically align with the GHS. The preceding sections detail information about the chemicals as well as control measures. The final section is for any other pertinent data.
The sections cover a number of issues. Sections 4, 5 and 6, for instance, list steps for responding to emergencies stemming from the chemical. These include first-aid, firefighting and accidental release measures.
Other sections define the nature of a chemical. What is it and what hazards are associated with it? If the chemical is a substance or mixture, what are the ingredients? What are the physical and chemical properties? These and other factors are covered in Sections 1, 2, 3, 9, 10, 11 and 12.
Other factors addressed in the SDSs include disposal guidelines, storage guidelines, associated regulations and shipping restrictions and requirements.
Caveats to the rules
OSHA has some exceptions to its new rules for SDSs. One particularly important designation is the exemption relating to articles. These items are exempt from the regulations because they do not release the chemical used in their development or present an exposure risk by any other means. For example, nitrile gloves do not need SDSs.
SDS regulations apply to several parts of the supply chain.
For items to be classified as articles, they must meet additional criteria. The product must have a specific design or shape that defines its end use. Disposable gloves are shaped to fit hands and provide barrier protection for those body parts, so they are articles.
One glove-specific exemption is medical-grade gloves. Unlike industrial-grade gloves, which receive oversight from OSHA, these products fall under the purview of the U.S. Food and Drug Administration (FDA) and are therefore not liable to the HCS provisions.
How this affects AMMEX and our distributors
AMMEX is currently updating our MSDSs to SDSs. Both distributors and customers have inquired about when the change will be finalized. Per the OSHA deadlines, we encourage all vendors to ensure their products are compliant by the June 1 deadline.