Following the Rule: Laboratory Safety Regulations and the Hazard Communication Standard

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By Daniel J. Scungio, MT(ASCP), SLS, CQA (ASQ)

This article was originally published in the Q4 2013 issue of CLMR.

Development of the Globally Harmonized System

 In 1987, the Occupational Health and Safety Administration (OSHA) promulgated its full Hazard Communication Standard (HazCom) for all employees in the United States who handle chemicals. The scope of the regulatory standard was broad; it encompassed chemical manufacturers and importers, shipyards, marine terminals, construction employers, and several other industries. The standard became more widely known as the “Right to Know” law.

The Hazard Communication Standard is comprehensive, but in 1990, OSHA promulgated the Chemical Hygiene Standard (also known as the Lab Standard). It was felt that while laboratory personnel tend to be well-educated, there were not many active comprehensive health and safety programs in the field.1 OSHA felt the laboratory setting was unique enough and that chemical exposures occurred in great enough numbers nationally to warrant a separate lab-specific standard for chemical safety. This set of regulations superseded the Hazard Communication Standard for laboratories. This Lab Standard contained new and different requirements for labs that increased the safety for their employees. These requirements included the need for a written chemical hygiene plan, the designation of a chemical hygiene officer, and specific education for employees covered by the standard.

As these laws came into effect in the United States, other events on the world stage were brewing that would lead to further changes for those who deal with hazardous chemicals. In 1992, the United Nations Conference on Environment and Development (UNCED), also known as the “Earth Summit,” put forth what was known as the International Mandate. The purpose of the mandate was to improve international efforts regarding the sound management of chemicals. The mandate stated, “A globally harmonized hazard classification and compatible labeling system, including material safety data sheets and easily understandable symbols, should be available, if feasible, by the year 2000.2

Over the next several years, working groups were created and were assigned various tasks in the process of the proposed harmonization. Three main groups worked with the areas of health and environmental hazard criteria, hazard communication, and physical hazard criteria. The completed system was endorsed by the United Nations Economic and Social Council in July 2003.

Many international agencies then put forth recommendations for implementing the Globally Harmonized System (GHS), some of them encouraging its immediate adoption. Over the last decade, different nations considered multi-phase implementation plans in order to meet UN recommendations.

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In May 2012, the United States adopted the GHS by updating OSHA’s Hazard Communication Standard. Adopting the complex changes to the standard will be a vast undertaking for chemical manufacturers who produce and ship large volumes of hazardous product. Because of the complexity, OSHA has created a timeline that includes multiple phases and deadlines for each step of the process.

Updates for the Hazard Communication Standard

One of the key changes included in the GHS process is the new name and standardized format of Safety Data Sheets (SDS). SDS (previously known as Material Safety Data Sheets or MSDS), throughout all countries that have adopted the GHS, will contain a standard format with 16 sections (see Figure 1). Chemical manufacturers in the United States have until Dec. 1, 2015, to comply with this standard SDS format.

SDS provides information for employers that help them manage the hazards associated with chemicals. Chemical composition, handling, storage, and waste disposal sections aid the employer in developing safe lab practices to enable chemical hygiene.

In the laboratory setting, there are two main reasons an SDS may be needed quickly; a spill situation or an exposure. Section Four of the SDS provides information for first aid in the event of an exposure. This includes information on the washing of skin or eyes and any necessary follow-up treatment. Section Six gives instructions in the event of an accidental release or a chemical spill. This section may provide information about any special precautions to take (including personal protective equipment) during the chemical spill clean-up. The arrangement of these SDS sections in the standard format can also be useful to help with employee training (Four = First Aid, Six = Spills).

Another key element of the GHS includes the use of standard pictograms on chemical labels and in the SDS. There are nine universal pictograms that should be used to help identify chemical hazards. Only eight of these pictograms are required by OSHA. Since the environmental hazard pictogram does not apply to employees, OSHA cannot mandate its use, but manufacturers will still be able to use this pictogram on labels and in SDS (see Figure 2).

The standard classification and labeling of hazardous chemicals is the third major component included in the adoption of the GHS. Chemical labels produced by manufacturers must include specific elements that enable the user to be able to easily identify the hazards associate with that chemical’s use (see Figure 3). By June 1, 2015, all U.S. chemical manufacturers will be required to label hazardous chemicals with:

  • Name, address, telephone number;
  • Product identifier;
  • Signal word;
  • Hazard statement(s);
  • Precautionary statement(s); and
  • Pictogram(s).

One of two signal words must be used on the label to help indicate the level of the severity of the chemical hazard. “Danger” is used to indicate more severe hazards and “warning” is used to indicate less severe hazards. Only one signal word may be used on a label. If a chemical contains multiple hazards warranting both signal words, then “danger” will be used.

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The hazard statement describes the nature and, if appropriate, the degree of the chemical hazard. It may contain a description of the route of entry of the chemical. Multiple hazard statements should be used as necessary. Some examples of hazard statements may be: “causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin” or “highly flammable liquid and vapor.”

Precautionary statements on a label describe the actions to take in order to minimize the effects of chemical exposure or to reduce problems associated with improper chemical storage or handling. Four categories of precautionary statements may be used: exposure prevention, spill and exposure response, storage, and disposal.

Implementation of the GHS

The first deadline in the United States’ rollout of the updated Hazard Communication was Dec. 1. By that date, all employees who handle hazardous chemicals must complete training on specific elements of the changes that were brought forth by the GHS. The training must include information about the format of SDS and new labeling elements including pictograms.

By June 1, 2015, chemical manufacturers, distributors, and importers will be required to comply with all of the changed elements of the HazCom Standard. So that these manufacturers will be able to have a transition period, they will have until Dec. 1, 2015, to ship chemicals that do not contain a GHS label.

The last deadline in the rollout plan created by OSHA is June 1, 2016. By this date, all employers must update their workplace hazard communication plans to comply with GHS. Any additional training related to newly identified health or physical hazards of chemicals must be completed. Because there are many steps to the process of adopting the updated Hazard Communication Standard, OSHA has allowed for a transition period. Employers may comply with the final standard, the current standard, or both until each deadline in the process has passed.

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References

  1. New Mexico State Laboratory, Chemical Hygiene Plan, January 2013 http://www.chemistry.nmsu.edu/Stockrm/ Chemical%20Hygiene%20Plan%20-%202013.pdf Last Accessed 10/6/2013
  2. Globally Harmonized System of Classification and Labelling of Chemicals (GHS), The Purple Book, 4th ed. United Nations, 15 July 2011.
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