The deadline for employers to have trained their employees on the federal Occupational Safety and Health Administration ("OSHA") revisions on new labeling and formatting for Safety Data Sheets ("SDS") is December 1, 2013. The modifications are intended to improve worker understanding of the hazards associated with chemicals in the workplace. The December 1 deadline is the first compliance date of OSHA's 2012 revised Hazard Communication System ("HCS"), which will be phased in through June 1, 2016.
By December 1, employers must have trained their workers on the new label elements and the SDS format. OSHA states that the training is needed early in the transition process because workers are already beginning to see the new labels and SDS on chemicals in the workplace. The training will provide employees with the information they need to better protect themselves from chemical hazards.
Training on label elements must include information on the type of information the employee would expect to see on the new labels, including:
- Product identifier- how the hazardous chemical is identified;
- Signal word- used to indicate the relative level of severity of the hazard;
- Pictogram- the use of the required size, shape and color of OSHA's required pictograms;
- Hazard statements- used to describe the nature of the hazards of a chemical;
- Precautionary statements- used to describe recommended measures to prevent or minimize adverse effects from exposure; and
- Name, address and phone number of the chemical manufacturer, distributor or importer.
The label element training should also address how an employee might use labels in the workplace, and a general understanding of how the elements work together on a label.
Training on the format of the SDS must include information on the standardized 16-section format, including the type of information found in the various sections, and how the information on the label is related to the SDS.
As with all training, according to OSHA, the training must be conducted in a manner that employees can understand, including employees who speak languages other than English, employees with limited vocabularies, and employees who are not literate.
More information is available at OSHA's Hazard Communication website: http://www.osha.gov/dsg/hazcom/index.html
If you have any questions concerning the content of this Legal Alert, please contact the following from our office, or the attorney with whom you normally consult.