This article is brought to you by Nexreg Compliance, Inc.
The fact sheets published by OSHA provides guidance for Training Requirements, Safety Data Sheets, and Labels/Pictograms for the revised Hazard Communication Standard known as HazCom 2012; based on the Globally Harmonized System (GHS).
Nexreg regulatory consultants have reviewed the fact sheets on Safety Data Sheets and Labeling to determine if there are any new or conflicting interpretations of the OSHA regulations. They found that while the guidance on Safety Data Sheets was consistent with their current understanding of the regulations, there were some facts about workplace labels that were previously unknown. For instance:
Workplace labels:
- Employers have option to create their own workplace labels
- Can either provide all the required info on the label from the manufacturer, or the product identifier and words, picture, symbols or a combination thereof, which in combination with other information immediately available to employees, provide specific information regarding the hazards of the chemicals
- For employers still using labeling that meets HazCom 1994, they can continue to use this system in the workplace, as long as, in conjunction with other information immediately available, provides all the health and physical hazards of a particular chemical
- If an employer chooses to use the pictograms in Appendix C (GHS symbols), these may have a black border rather than red.
- If an employer transfers hazardous chemicals from a labeled container to a portable container only intended for immediate use by that employee, no labels are required for the portable container.
For more information MSDS Online has a summary of the information contained in the fact sheets (Please refer to the link) as well as links to other useful information.