Association Insights: Are You Ready for New Hazard Communication Requirements?

In March 2012, OSHA revised its Hazard Communications Standard (HCS) to align with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Included in the changes impacting printing operations are a new labeling system and a mandatory standardized format for Safety Data Sheets (SDSs).

The new requirements under the standard are being phased in and will be complete by June 1, 2016. The first deadline that printing operations needed to meet was December 1, 2013, the date by which all employers were to have conducted employee training covering the new label and SDS formats.

Companies are urged to take the following steps to update or develop a compliant Hazard Communication program:

1. If you are a Printing Industries of America’s member, you can use your member login to access the dedicated Hazard Communication page at www.printing.org/hazcom. Here you will find the materials that Printing Industries of America is providing free of charge to assist you with compliance, including:

• A guidebook that provides information about the revised Hazard Communication Standard and compliance requirements.

• A video and PowerPoint presentation that can be used by the member to train their employees about the revised Hazard Communication Standard.

• Other supporting materials such as a transition guide, sample written program, compliance checklist, training forms, sample letters, etc.

2. If you have not already conducted initial employee training that was due by December 1, 2013, do so as soon as possible! Initial employee training must cover the new labeling elements, including product identifiers, signal words, hazard statements, precautionary statements, and pictograms as well as the standardized format of Safety Data Sheets, which are replacing Material Safety Data Sheets (MSDS).

Employees required to be trained are those who are directly exposed to or could be exposed to a product with a hazardous chemical. This would include employees involved in prepress, production, maintenance, shipping and receiving, and anyone else who might be exposed to a chemical.  

3. If your facility does not have one written hazard communication program, a GHS-compliant program must be developed. If you need one, a sample can be found at www.printing.org/hazcom. Any existing program should be reviewed to ensure that it is current, and as a minimum, any references to MSDS need to be replaced with SDS. The program should also be reviewed to ensure that the other necessary elements reflect the current practices, such as the location of the SDSs, responsible parties, etc.

4. If the inventory of products and chemicals that are currently being used has not been updated, a comprehensive inventory of all products needs to be conducted.

5. Compare the inventory of products and chemicals to ensure that either an MSDS or SDS is present and up to date. (Until June 1, 2015, both MSDS and SDS are acceptable. After that date only SDS will be allowed.) For any chemical or product that does not have an MSDS or SDS, one should be obtained. Any MSDS that is more than several years old should be replaced with an updated sheet.

6. Determine what in-plant container labeling system will be used under the revised standard that will not contradict the GHS labeling system. If updates are needed, they must be completed by June 1, 2015, when the vendors must have made the changes to their shipping containers to meet the new requirements. Many printing companies use the Hazardous Material Information System (HMIS) approach. If this system will be continued, additional information and training will be required for employees.

Gary Jones is vice president of EHS Affairs for Printing Industries of America. Caitlin Seiler is the association’s EHS specialist. If there are any questions about the revised requirements, members are encouraged to contact the EHS Affairs Department at [email protected] or 412-259-1794. For more information about Printing Industries of America, visit MyPRINTResource.com/10013918.