Hazard Communication Standard, General Industry – Regulation 29 CFR 1910.1200
Enforcement from Oct 2021-Sept 2022
Total citations: 29
Total inspections: 18
Total proposed penalties: $124,086
Most Frequently Violated OSHA Standard Ranking – Number 2
Industries most often violating the hazard communication standard:
- Manufacturing: $98,358 in proposed penalties based on 21 citations and 14 inspections
- Wholesale Trade: $20,442; 5; 2
- Transportation and Warehousing: $3,414; 2; 1
- Construction: $1,873; 1; 1
About the Standard
OSHA aligned its Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS in order to provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. The change was also intended to help reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store and use hazardous chemicals while providing cost savings for American businesses that periodically update safety data sheets and labels for chemicals covered under the hazard communication standard.
Major Provisions of the Standard
In order to ensure chemical safety in the workplace, information about the identities and hazards of the chemicals must be available and understandable to workers. OSHA’s Hazard Communication Standard (HCS) requires the development and dissemination of such information:
- Chemical manufacturers and importers are required to evaluate the hazards of the chemicals they produce or import, and prepare labels and safety data sheets to convey the hazard information to their downstream customers;
- All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers and train them to handle the chemicals appropriately.
- Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
- Labels: Chemical manufacturers and importers must 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: Have a specified 16-section format.
- Information and training: Employers are required to train workers on the new label elements and safety data sheets format to facilitate recognition and understanding. What are the major changes to the hazard communication standard?
The GHS does not include harmonized training provisions but recognizes that training is essential to an effective hazard communication approach. The Hazard Communication Standard (HCS) requires that workers be retrained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safety data sheets.
Employer Responsibilities
Employers must ensure that the SDSs are readily accessible to employees for all hazardous chemicals in their workplace. This may be done in many ways. For example, employers may keep the SDSs in a binder or on computers, as long as the employees have immediate access to the information without leaving their work area when needed and a back-up is available for rapid access to the SDS—in the case of a power outage or other emergency. Furthermore, employers may want to designate a person(s) responsible for obtaining and maintaining the SDSs. If the employer does not have an SDS, the employer or designated person(s) should contact the manufacturer to obtain one.
FAQs About the Standard
Q: When packaging falls below a certain container size, it may be difficult to display all HCS pictograms and text in such a limited space according to the labeling requirements for small packaging under the standard. Does OSHA allow any reduction of the number of required label elements for small packaging?
A: OSHA reviews labeling small packages on a case-by-case basis to determine whether a practical accommodation is warranted.
Q: Does OSHA limit the number of precautionary statements that should appear on the label?
A: No, OSHA does not have a limit on the number of precautionary statements that appear on the label. OSHA requires all of the appropriate precautionary statements to appear on the label to warn users of the hazards of the chemical in question. However, OSHA does allow for some flexibility when identifying the appropriate precautionary statement(s) for labels. For instance, precautionary statements may be combined or consolidated to save label space. “Keep away from heat, sparks and open flame,” “Store in a well-ventilated place” and “Keep cool” can be combined to read “Keep away from heat, sparks and open flame and store in a cool, well-ventilated place.”
Q: Can you have a blank or blacked-out pictogram on a label?
A: Labels may not contain blank “square-on-point” (red borders with no symbol). Blacked out pictogram borders are compliant with the requirements of HCS 2012 as they are not a “square red frame set at a point without a hazard symbol.” However, if a blank red frame is not fully covered or filled in, the label would not be in compliance.
Q: How should the unknown acute toxicity statement be communicated on labels and SDSs?
A: The unknown acute toxicity statement is required on the label and Section 2 of the SDS where a chemical is classified as acutely toxic, the classification is not based on testing of the mixture as a whole, and there are any relevant ingredients of unknown acute toxicity by any relevant route of exposure. Classifiers can present the unknown acute toxicity information on labels and SDSs either as a single statement or as multiple statements, where routes are differentiated. If there is an unknown acute toxicity by more than one route, and the classifier chooses to provide one statement in order to save space on the label or SDS, then the route with the highest percentage unknown toxicity will be used in the statement. WMHS
Resources
Visit www.osha.gov/hazcom for information about safety data sheets, pictograms, labeling requirements and other hazcom-related topics.
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