It seems like quite some time ago now that OSHA completed their 2012 final rule revising the Hazard Communication Standard, also known as the ‘right to know’ regulation. For many companies, the new regulations were looked over and then largely forgotten about. If that is the case for you, consider this your wakeup call!
You now have less than a year to get in compliance with these regulations, and if you fail to do so you can be subject to fines and other penalties. According to OSHA, the deadline for compliance is June 1, 2016. Employers need to have all their workplace labeling procedures in place and the employees trained by this date in order to avoid problems.
According to a memo from OSHA released on February 9th, 2015 it is expected that many facilities (specifically chemical suppliers) would likely miss the deadline. While this is certainly a problem, they did say that OSHA inspectors should ‘take into account good-faith efforts.’ This means even if you aren’t sure that you’ll be able to be completely in compliance with the standards, making a good effort may reduce or eliminate potential fines.
Another important deadline for any distributors of chemicals is December 1st, 2015. This is the date by which all distributers need to be using labels that meet the new set of standards. Whether it is your company’s primary job to distribute chemicals or it is just a small part of your business, it is essential to get in compliance by this date. Many other businesses will be relying on the distributors to have their labels in compliance by this time.
Of course, for most facilities it is still possible to get into compliance with the regulations before the June, 2016 deadline. The following tips will help you to get your facility in compliance as quickly as possible so you can avoid all risk of OSHA fines or citations.
The chemical labeling requirements are fairly specific so it is a good idea to learn about them as soon as possible. The following information must be on each container that holds a hazardous chemical.
- Product Identifier – This will identify what the product in the container is.
- Signal Word – Signal words like ‘CAUTION’ or ‘WARNING’ need to be in large print.
- Hazard Statement – A statement about what the specific hazard is for the materials within the container.
- Pictogram – The pictograms help improve visual communication and allow people to quickly understand the risk even if they can’t read the print on the label. This is important when viewing containers from some distance away.
- Precautionary Statement – This statement will let people know what cautions they should take when working with this hazardous material. Things like wearing gloves or respiratory equipment can be mentioned here.
Each of these things must be clearly printed and easy to see for anyone working with or around the containers. In the vast majority cases, these items will be printed on a label and applied to the container. According to OSHA, however, it is also permitted to “use signs, placards, process sheets, batch tickets, operating procedures or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required.”
One of the most important points in that comment from OSHA is that if you are going to use an alternative to labels, it must be made clear which container the item is referring to. This means you cannot just have a general procedure handbook for a department as it won’t be able to clearly identify the proper containers.
For the vast majority of situations, a label is going to be much faster and easier. If you have a LabelTac printer in your facility, it will also be the least expensive way to ensure this information is available to employees as required by OSHA.
Understanding the Requirements
If you have not already gone through the revised standards, that should be a priority. These standards require that any manufacturer or importer of hazardous chemicals or other materials must classify them properly. In addition, distributors of these substances have to transmit this information to the employers to whom they will be delivered.
The employers are then required to share this information with their employees so that they are aware of what they are potentially be exposed to and what safety steps they must take. Of course, providing employees with the proper personal protection equipment is also extremely important.
As implied above, employers also need to make sure everyone in the facility knows how to handle these types of materials. This means training them on how to work with the hazardous materials in normal circumstances as well as how to respond to spills or other emergency situations that might potentially present themselves.
Remember, all of these things will take time to learn and implement so with the deadline less than a year away it is a good idea to start looking into them as quickly as possible. Leaving these things to the very last minute can cause your facility to be found in violation of the rules and OSHA isn’t likely to be understanding if they believe you did not begin your implementation until just before the deadline.
Getting In Compliance
The first thing you’ll want to do is evaluate your current situation so you can understand what needs to be changed. In most cases, this will involve learning the details of the new standards, and then looking through your facility to see where problems may exist.
When doing this it is important to look at your facilities policies as well as how they are carried out in practice. Many facilities, for example, will have their policies and procedures up to date with the new standards, but the employees aren’t actually following them. Another common issue is that older containers, signs or labels will still be using the outdated standards.
Updating your hazard communication standards in the facility really doesn’t have to be too difficult. In many cases, the biggest issue that will need to be addressed is the labels on containers or in areas where chemicals or other hazardous materials are used. Updating these labels can be done by ordering new ones from a third party printer, or for a faster and less expensive solution, printing the new labels off yourself.
If your facility has a LabelTac printer, for example, you can quickly print new labels as they are needed. This can help you to avoid ordering and paying for more than you will need and it will also help avoid delays in the event that you don’t order enough. These printers can be used to print what you need in an ‘on demand’ fashion that can help your facility get in compliance much more quickly.
Another important part of getting your facility in compliance is educating the employees. There are two main aspects of employee education when it comes to GHS Compliance:
- Recognizing Hazards – The first step is to make sure all employees can recognize warning signs and labels and know what they mean. Teaching everyone what each of the symbols means, for example, will help ensure they know how to react in any situation involving hazardous materials.
- Proper Labeling – The next important item employees need to be trained on is proper labeling and signs. If an employee sees that a chemical container has an outdated label on it, for example, they should know to use the LabelTac printer to make a new one or else report it to someone who can do it for them. This will help ensure the facility gets in compliance and stays that way.
OSHA has a lot of information about how to have an effective hazard communication program right on their website. They also offer consultation or on-site training for many types of companies. Visiting the OSHA website can provide you with a wealth of information that can help you to get in compliance. Make sure you take advantage of it now so you can be sure to be in compliance prior to June 1st, 2016.
- GHS Labeling – The Do’s and Don’ts
- Process Safety Management of Highly Hazardous Chemicals – 1910.119
- OSHA Empowers Employees
- Hazard Harmony Between OSHA, NFPA, and HMIS
- OSHA’s Priority Areas in Workplace Safety