SMACNA - Western Washington Risk Management Program 1200 Westlake Avenue North, Suite 501 Seattle, WA 98109 phone 206-285-4144 / fax 206-283-6580 PG: 1 of 5 FR: Mary P. Hollins, Director of Risk Management, mary@hollinsrmc.com cell 206-270-9044 RE: Globally Harmonized System of Classification & Labeling of Chemicals - HAZCOM (GHS) Overview of Requirements & Information about Compliance Resources WAC 296-901-140 & 29 CFR Part 1910.1200 Introduction For the first time since 1983, both OSHA and (by mandate) DOSH have adopted new rules related to informing employers and employees about chemical hazards found in the workplace. These have historically been referred to as Hazard Communication or HAZCOM. The new rules contain revisions which align them with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals. They are commonly referred to as HAZCOM (GHS.) The purpose of this memo is to provide a brief overview of how the rules have changed. It will also provide information about resources you may want to consider using to update and implement your Accident Prevention Program. These include such items as: FAQs, sample APP materials, training tools, access to electronic pictograms via download, contact information for reps of various companies that can be hired to help you manage your Safety Data Sheets (SDSs.) (See Suggested Resources below re management of SDSs & labels.) Here are some key concepts to keep in mind: It is unwise to think that this rule is a simple update that will require minimal time and effort for your company to implement. In fact, just the opposite is true! The OSHA & WAC rules adopted the same new language and requirements. The major difference is timing of implementation. Both have a schedule that spreads the implementation out over three (3) years. However, the WAC rule s implementation dates for employers begin later than OSHA s. Most of you will only need to concern yourself solely with the DOSH rule. Information about the OSHA rule is included in case you have work on a federal project &/or are required by a GC &/or client to adhere to the OSHA rule. Because the rules are substantially similar, all resource materials developed for both are applicable to both rules EXCEPT for the implementation dates. During the transition period to the effective completion dates noted in the rules, employers may comply with either the current rule, the new rule or both.
PG: 2 of 5 Implementation Schedule WHO WHAT DOSH By: OSHA By Employers Train employees on the safety data sheet (SDS) format and new label elements. June 1, 2014 December 1, 2013 Chemical manufacturers and importers Comply with new SDS and label requirements. June 1, 2015 June 1, 2015 Distributors Not to ship unless container has GHS (Global Harmonization System) label. December 1, 2015 December 1, 2015 Employers Update labels on "workplace" containers and train employees on newly identified hazards. Update the Hazard Communication Program, as needed. June 1, 2016 June 1, 2016 All Transition Period Until the dates listed in this table you may comply with the: New requirements in WAC 296-901-140. And/OR Current hazard communication rules May comply with: Either 29 CFR 1910.1200 (the final new standard), OR the current standard, OR both
PG: 3 of 5 Summary of Major Changes, Required Actions & Suggested Resources Summary of Major Changes to the Hazard Communication Standard Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures. Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. Safety Data Sheets (SDSs): Will now have a specified 16-section format. (These entirely replace MSDSs.) Information and training: Employers are required to train workers by OSHA by December 1, 2013 (by DOSH by June 1, 2014) on the new labels elements and safety data sheets format to facilitate recognition and understanding. Required Actions Train employees regarding the new rule requirements regarding new SDS format and label elements Update/create a list of chemicals used by your company Collect newly-produced Safety Data Sheets (SDSs) for each chemical If applicable, create and use new secondary containers that comply with the new rule Update your APP to reflect how HAZCOM (GHS) will be handled by your company While the first deadline relates to worker training, as soon as feasible, employers would do well to make decisions and begin to take action about how they intend to manage SDSs and labels. Suggested Resources DOSH The new OSHA-mandated WAC safety & health rule, which was adopted on March 5, 2013, became effective on April 15, 2013: (WAC 296-901-140 Globally Harmonized System of Classification & Labeling of Chemicals ) It is commonly referred to as HAZCOM (GHS). This rule replaced the original Hazard Communication rule adopted back in 1984. DOSH was forced to develop and adopt its rule on an expedited basis to meet the 180 day federal requirement to adopt a rule at least as effective as OSHA s. The WAC rule adopted the same new language and requirements as the OSHA rule. Again, timing limitations forced DOSH to adopt a rule that was substantially similar including a similar implementation schedule spread out over three (3) years. To assist employers, employees, manufacturers, vendors and other stakeholders, DOSH has developed and posted a HAZCOM webpage located at http://www.lni.wa.gov/safety/topics/atoz/ghs/ At this site, readers can access information about the rule changes and download a number of materials about the rule. Many are still in the development stage so referral to the OSHA link is posted.
PG: 4 of 5 Suggested Resources OSHA On March 26, 2012 OSHA adopted a new rule which became effective on May 25, 2012. The Hazard Communication standard was revised to align it with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals. It is commonly referred to as HAZCOM (GHS). (29 CFR Part 1910.1200 Hazard Communication ) This rule replaced the original Hazard Communication rule adopted back in 1983. This update to the Hazard Communication Standard provides a common and coherent approach to classifying chemicals and communicating hazard information on labels and Safety Data Sheets SDSs.) To assist employers, employees, manufacturers, vendors and other stakeholders, OSHA has developed and posted a HAZCOM webpage located at https://www.osha.gov/dsg/hazcom/index.html At this site, readers can access explanations about the rule changes and download a number of materials about the rule including: a new fact sheet (PDF*) that reviews the new training requirements https://www.osha.gov/publications/osha3642.pdf new QuickCards that review the new pictogram label requirements https://www.osha.gov/dsg/hazcom/ghsquickcards.html a brief (PDF*) on labels and pictograms http://www.osha.gov/publications/osha3636.pdf Suggested Resources Other The most time-consuming tasks related to compliance with the new rule are the management of Safety Data Sheets (SDSs) for each chemical used and, if applicable, creation of secondary container labels. While worker training deadlines are a ways off, employers would be wise to make decisions and take action as soon as feasible - about how they intend to gather and distribute SDSs, as well as create and affix secondary container labels PRIOR to these training dates. Below is a list of companies that have been established to assist employers with these tasks. Each employer is encouraged to contact any or all of these to help you comply. For your convenience, names of company reps, along with their contact info, has been included. Here are a list of questions you may want to consider in deciding to hire outside help &/or which resource to hire: What is the company s history? (e.g., industry-based? trade-based? What pricing structures are used? (e.g., projected &/or actual # of SDSs? # of workers?) What services are included &/or available to add-on? (e.g., ability to create specific lists with SDSs by job, trade or other criteria which may be needed for LEED or other ECO projects?) What is availability/accessibility of technical support including access to SDSs on demand to satisfy a request? What about copies electronically via email, website access &/or print? What employee training &/or secondary container label resources are available? What service is available and at what cost to assist with creation of employer-specific list of chemicals &/or to assist with gathering and maintaining SDSs?
PG: 5 of 5 Safety Data Sheet (SDS) Management Options COMPANY REP CONTACT INFO COMMENTS SUCCEED MANAGEMENT SOLUTIONS LLC 25191 SW Parkway Ave Ste 105 Wilsonville, OR 97070 www.succeedms.com SDS BINDERWORKS, INC. 3066 104 th Street Urbandale, IA 50322 www.sdsbinderworks.com 3E COMPANY 3207 Grey Hawk Court Ste 200 Carlsbad, CA (760) 602-8700 www.3ecompany.com MSDSonline 350 North Orleans Street Ste 950 Chicago, IL 60654 www.msdsonline.com Curt Shaw Office (503) 783-1915 Fax (503) 682-0266 Cell (503) 409-6700 Curt.s@succeedms.com Scot Stoltenberg Office: (515) 334-2619 Fax (515) 334-2620 DID (877) 433-7774 scot@sdsbinderworks.com Maggie Metzler 24/7 # (760) 602-8700 Fax (760) 918-4162 DID (760) 602-8890 MMetzler@3ECompany.com Anthony (Tony) Szajowski Fax (866) 320-1021 DID (312) 881-2906 aszajowski@msdsonline.com Discount for AMS/SMART clients? Discount for SMACNA members