Training Requirements for the new

Hazardous Communications Standard

Michael J. Johnston
Executive Director Standards and Safety
04/27/2024 1
 Continuing Education Units

• NECA is an Authorized Provider by the International Association for

Continuing Education and Training (IACET) and offers IACET
Continuing Education Units (CEUs) for MEI programs that quality under
the ANSI/IACET 1–2007 Standard.

• 0.15 CEUs = 90 minutes

04/27/2024 2
 Earning CEUs

• To earn IACET CEUs for this training, attendees must attend

95% of the presentation.

• Each attendee must take the learning assessment quiz and

achieve a score of at least 75%.

• Complete and submit an electronic evaluation upon

completion of the training.

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 Objectives

• Explain the need and use of a Global Harmonization System –

GHS
• Provide the required training for employees relative to the
new label elements and new SDS format.

• Describe the hazard classification and signal words

• Provide a review of the new label requirements in the
Hazardous Communication Standard – HCS
• Review the new criteria for safety data sheets – SDS

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 Overview

• Exposure to hazardous chemicals is one of the most serious

threats facing American workers today.

• OSHA revised its Hazard Communication Standard (HCS) to

align with the United Nations’ Globally Harmonized System
of Classification and Labeling of Chemicals (GHS) and
published it in the Federal Register in March 2012 (77 FR
17574).

04/27/2024 5
 Action and Timeline – Transition

• Dec. 1, 2013 Train employees on new label elements and SDS

format – Employers
• June 1, 2015 Comply with modified provisions of the Final
Rule – Manufacturers, Importers, Distributors, and employers.
• June 1, 2016 Update alternate workplace labeling and hazard
communication program as necessary and provide additional
training for newly identified physical or health hazards.

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 Significant Revisions to HCS

• Three significant changes contained in the revised standard

include additional hazard classification, require the use of new
labeling elements, and use of a standardized format for Safety
Data Sheets (SDSs)

• The new label elements and SDS requirements will improve

worker understanding of the hazards associated with the
chemicals in their workplace.

04/27/2024 7
 HCS Revisions

• Hazard classification: Provides specific criteria for

classification of health and physical hazards, as well as
classification of mixtures.
• Labels: Chemical manufacturers and importers will be
required to provide:

• Label with a harmonized signal word

• A pictogram (graphic)
• Hazard statement for each hazard class and category.
• Precautionary statements

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 HCS Revisions

• Safety Data Sheets: Will now have a specified 16-section

format.

• Information and Training: The final HCS will require that

workers are trained within two years of the publication of the
final rule to facilitate recognition and understanding of the
new labels and safety data sheets.

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 OSHA Final Rule – Effective Date

• 12/1/13: All employees must be trained on new label elements

and SDS format
• 6/1/15: Manufacturers and distributors must comply with all
modified provisions except that distributors have until 12/1/15
to provide revised labels for all products shipped.
• 6/1/16: OSHA enforcement starts: Employers must update all
labels and HazCom program, provide additional training for
workers on newly identified physical or health hazards
• Note: During transition period, employers can comply with old
or new standard as far as labels and SDSs.
04/27/2024 10
 Required Training

• To help companies comply with the revised standard, OSHA

is phasing in the specific requirements over several years
(December 1, 2013 to June 1, 2016).
• By December 1, 2013 employers are required to train
employees on the following:

• New labeling elements in HCS and,

• Standardized format for Safety Data Sheets (SDSs)

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 What is the GHS?

• The Global Harmonization System (GHS) is a common and

coherent approach to defining and classifying hazards, and
communicating information on labels and safety data sheets.

• Target audiences include workers, consumers, transport

workers, and emergency responders.

• Provides the underlying infrastructure for establishment of

national, comprehensive chemical safety programs.
 Why have a GHS?

• Most countries are challenged with the requirement to

specifically regulate all hazardous chemical products.

• In the United States, there are an estimated 650,000 such

products.

• Adoption of uniform requirements for information to

accompany the product helps globally address protection
needs.
 GHS Benefits

• Promotes safer transportation, handling and use of chemicals

and improve common understanding of hazards.

• Helps protect workers, consumers and potential exposed

populations globally.

• Increases compliance and reduces costs for companies

involved in national and international activities

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 What is an SDS?

• SDS stands for Safety Data Sheets

• Replaces the previous acronym MSDS – Material Safety Data

Sheets

• Essentially functions the same as before, but must include

consistent elements.

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 Hazard Classification

• Hazard determination/classification are self-classification

processes – manufactures and importers must classify each
chemical, determine appropriate hazard class and category
based on evaluation of full range of available data/evidence.

• Appendix A defines health and physical hazards

• Appendix B includes parameters to evaluate health hazard data
• Appendix F pertains to carcinogens

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 Physical Hazards

1910.1200 Appendix A (information in part)

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 Health Hazards

1910.1200 Appendix A (information in part)

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 HazCom GHS Training

• Training is integral hazard communication.

• Systems should identify appropriate education and training for
GHS target audiences who must interpret label and/or SDS
information and take action in response to chemical hazards.
• Training should address: workers, emergency responders, and
those involved with preparation of labels, SDS and HazCom
strategies as part of risk management systems.
• Systems should also educate consumers in interpreting label
information on products they use.

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 Label Information

• Product Identifier

• Signal Word

• Precautionary Statement(s)

• Name, address and phone number of

the chemical manufacturer,
distributor, or importer
• Pictogram

• Hazard Statement(s)
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04/27/2024 21
 Product Identifier

• How the hazardous chemical is identified.

• Can be (but is not limited to) the chemical name, code number
or batch number.
• The manufacturer, importer or distributor can decide the
appropriate product identifier.
• The same product identifier must be both on the label and in
Section 1 of the SDS (Identification).

04/27/2024 22
 Signal Word(s)

• A signal word is used to indicate the relative level of severity

of hazard and alert the reader to a potential hazard on the
label.
• Two signal words “DANGER” and “WARNING”

• Danger – Most severe degree of hazard

• Warning – Less severe than danger

04/27/2024 23
 Signal Word – Danger

• Indicates an imminently hazardous situation which, if not

avoided, will result in death or serious injury.
• This signal word is to be limited to the most extreme
situations.
• This signal word should not be used for property damage
hazards unless personal injury risk appropriate to this level is
also involved.

• ANSI Z535.3
04/27/2024 24
 Signal Word – Warning

• Indicates a potentially hazardous situation which, if not

avoided, could result in death or serious injury.

• This signal word should not be used for property damage

hazards unless personal injury risk appropriate to this level is
also involved.

• ANSI Z535.3

04/27/2024 25
 Signal Words (cont.)

• There will only be one signal word on the label no matter how
many hazards a chemical may have.

• If one of the hazards warrants a “Danger” signal word and

another warrants the signal word “Warning,” then only
“Danger” should appear on the label.

04/27/2024 26
 Precautionary Statement(s)

• Providing a statement describing recommended measures that

should be taken to minimize or prevent adverse effects
resulting from exposure to a hazardous chemical or improper
storage or handling.

• Example: Wear respirator, wear protective eyewear, Use in

well ventilated area, etc.

04/27/2024 27
 OSHA Pictograms

• OSHA’s required pictograms must be in the shape of a square

set at a point and include a black hazard symbol on a white
background with a red frame sufficiently wide enough to be
clearly visible.
• A square red frame set at a point without a hazard symbol is
not a pictogram and is not permitted on the label.
• OSHA has designated nine pictograms under this standard for
application to a hazard category.

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 OSHA Pictograms

Circle Over Flame Flame Toxicity Explosive

Corrosive Gas Cylinder Health Hazard Environmental

Hazard
04/27/2024 29
04/27/2024 30
 Hazard Statement(s)

• Describes the nature of the hazard(s) of a chemical, including,

where appropriate, the degree of hazard.

• For example: “Causes damage to kidneys through prolonged

or repeated exposure when absorbed through the skin.”

04/27/2024 31
 Hazard Statement(s)

• All of the applicable hazard statements must appear on the

label.
• Hazard statements may be combined where appropriate to
reduce redundancies and improve readability.
• The hazard statements are specific to the hazard
classification categories, and chemical users should always
see the same statement for the same hazards, no matter what
the chemical is or who produces it.

04/27/2024 32
 Hazard Statement Example

• The employee should be instructed that with the new format,

Section 8 (Exposure Controls/Personal Protection) will always
contain information about:

• Exposure limits
• Engineering controls
• Ways to protect yourself
• Personal Protective Equipment - PPE

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 Label Quick Card

04/27/2024 34
 Safety Data Sheets – SDS

• The Hazard Communication Standard (HCS) requires

chemical manufacturers, distributors, or importers to provide
Safety Data Sheets (SDSs) to communicate the hazards of
hazardous chemical products.

• As of June 1, 2015, the HCS will require new SDSs to be in a

uniform format, and include 16 section numbers, the headings,
and associated information under the headings.

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 Section 1 – Identification

• Includes product identifier; manufacturer or distributor name,

address, phone number; emergency phone number;
recommended use; any restrictions on use.

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 Section 2 – Hazard Identification

• Includes all hazards regarding the chemical; required label

elements.

In part, See SDS Sample PDF

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 Section 3 – Composition

• Composition/information on ingredients includes information

on chemical ingredients; trade secret claims.

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 Section 4 – First Aid Measures

• First-aid measures includes important symptoms/effects,

acute, delayed; required treatment.

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 Section 5 – Fire-Fighting Measures

• Fire-fighting measures lists suitable extinguishing techniques,

equipment; chemical hazards from fire.

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 Section 6 – Accidental Release

• Accidental release measures lists emergency procedures;

protective equipment; proper methods of containment and
cleanup.

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 Section 7 – Handling and Storage

• Handling and storage lists precautions for safe handling and

storage, including incompatibilities.

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 Section 8 – Exposure Controls PPE

• Exposure controls/personal protection lists OSHA’s

Permissible Exposure Limits (PELs); Threshold Limit Values
(TLVs); appropriate engineering controls; personal protective
equipment (PPE).

In part, See SDS Sample PDF

04/27/2024 43
 Section 9 – Chemical Characteristics

• Physical and chemical properties lists the chemical’s

characteristics. For example, how a chemical behaves in cold
or heat.

In part, See SDS Sample PDF

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 Section 10 – Chemical Stability

• Stability and reactivity lists chemical stability and possibility

of hazardous reactions. For example, how the chemical reacts
to exposure to elements such as wetness, dampness or other
chemicals.

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 Section 11 – Toxicology

• Toxicological information includes routes of exposure; related

symptoms, acute and chronic effects; numerical measures of
toxicity.

In part, See SDS Sample PDF

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 Sections 12 through 15

• OSHA does not enforce these requirements since they are

regulated by other Agencies

Section 12, Ecological information*

Section 13, Disposal considerations*
Section 14, Transport information*
Section 15, Regulatory information*

04/27/2024 47
 Section 16 – Other Information

• This section indicates when the SDS was prepared or when

the last known revision was made.

• The SDS may also state where the changes have been made to
the previous version.

• You may wish to contact the supplier for an explanation of the

changes. Other useful information also may be included here.

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 Detailed Information

• See Appendix D of 29 CFR 1910.1200 for a detailed

description of required Safety Data Sheet contents.

• Table D.1 provides the minimum information required for

SDS.

04/27/2024 49
 Call to Action

• Training of workers can begin immediately.

• As new products are ordered, make sure to keep SDS

documents in new formats.

• Companies that manufacture products will have to conform to

both employer and manufacturer provisions of revised rule.

04/27/2024 50
 Employer Responsibilities

• Employers must ensure that the SDSs are readily accessible to

employees for all hazardous chemicals in their workplace.
• As an example, employers may keep the SDSs in a binder or
on computers as long as the employees have immediate access
to the information without leaving their work area when
needed and a back-up is available for rapid access to the SDS
in the case of a power outage or other emergency.

04/27/2024 51
 Employer Responsibilities (cont.)

• In addition, employers may want to designate a person(s)

responsible for obtaining and maintaining the SDSs.

• If the employer does not have an SDS, the employer or

designated person(s) should contact the manufacturer to
obtain one.

04/27/2024 52
 Additional Resources

• OSHA’s Hazard Communication website

(http://www.osha.gov/dsg/hazcom/index.html) has the
following QuickCards and OSHA Briefs to assist employers
with the required training.

• Label QuickCard (English/Spanish)

• Pictogram QuickCard (English/Spanish)
• Safety Data Sheet QuickCard (English) (Spanish)
• Safety Data Sheet OSHA Brief
• Label/Pictogram OSHA Brief
04/27/2024 53
 Hazardous Comm. Standard

• CFR 1910.200 Standard can be found on OSHA’s Hazard

Communication Safety and Health Topics page, located at:
http://www.osha.gov/dsg/hazcom/index.html

• Hazard Communication Standard Facts

https://www.osha.gov/dsg/hazcom/HCSFactsheet.html

04/27/2024 54
 SDS Information

• Safety Data Sheets and information are available at

www.msds.com.

• Several organizations can provide training programs either

online or face-to-face programs.

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 Review Questions

• 1. What is the Globally Harmonized System?

• A. The Globally Harmonized System (GHS) is an

international approach to hazard communication, providing
agreed criteria for classification of chemical hazards, and a
standardized approach to label elements and safety data
sheets.

04/27/2024 56
 Review Questions

• 2. Why did OSHA decide to modify the Hazard

Communication Standard to adopt the GHS?
• A. OSHA has modified the Hazard Communication Standard
(HCS) to adopt the GHS to improve safety and health of
workers through more effective communications on chemical
hazards.

04/27/2024 57
 Review Questions

• 3. What is the phase-in period in the revised Hazard Communication

Standard?
• A. Dec. 1, 2013 Employees required to be trained on new safety label
elements and new SDS formats
• June 1, 2015* Compliance with all modified provisions of this final rule,
except:
• December 1, 2015 – The Distributor shall not ship containers labeled by
the chemical manufacturer or importer unless it is a GHS label
• June 1, 2016 – Update alternative workplace labeling and hazard
communication program as necessary, and provide additional employee
training for newly identified physical or health hazards.
04/27/2024 58
 Review Questions

• 4. Why must training be conducted prior to the compliance

effective date?
• A. OSHA is requiring that employees are trained on the new
label elements (i.e., pictograms, hazard statements,
precautionary statements, and signal words) and SDS format
by December 1, 2013, while full compliance with the final
rule will begin in 2015.

04/27/2024 59
 Review Questions

• 5. What are the major changes to the Hazard Communication Standard?

• A. The three major areas of change are in hazard classification, labels,

and safety data sheets.
• Hazard classification: The definitions of hazard have been changed to
provide specific criteria for classification of health and physical hazards,
as well as classification of mixtures.
• Labels: Chemical manufacturers and importers will be required to
provide a label that includes a harmonized signal word, pictogram, and
hazard statement, and precautionary statements for each hazard class
and category.
• Safety Data Sheets: Will now have a specified 16-section format.
04/27/2024 60
 Summary

• There are new label requirements in the Hazardous

Communication Standard – HCS
• U.S. Implementation and Use of a Global Harmonization
System – GHS
• There is required training for employees relative to the new
label elements.
• There is new criteria for safety data sheets – SDS

04/27/2024 61
 Training Requirements for the new
Hazardous Communications Standard

Michael J. Johnston
Executive Director Standards and Safety
04/27/2024 62