Are You in Compliance with OSHA's Revised Hazard Communication Standard?

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In 2012, the Occupational Safety and Health Administration issued its Revised Hazard Communication Standard (HCS) to align with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals.  The intent of the HCS is to provide a common and understandable approach to classifying chemicals used in the workplace, and communicate the hazardous information on labels and Safety Data Sheets, formerly known as Material Safety Data Sheets (MSDS).  Employer responsibilities have been phased in, with the last deadline approaching on June 1, 2016.
 
Does my establishment need to comply?
 
1.     The HCS should apply to most hospitality employers because they typically use various types of hazardous chemicals, including degreasers, soaps, oven cleaners, floor cleaners, sanitizers, and drain openers, in the workplace.
 
What's new?
 
1.     Chemical manufacturers and importers are required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category.  They must also provide precautionary statements.
 
2.     Safety Data Sheets will replace the MSDS, and have a specified, 16-section format.
 
3.     OSHA has prepared Label, Pictogram, and Safety Data Sheet Quick Fact cards, in both English and Spanish, for use in training employees.
 
What are my obligations as an employer?
 
1.     Employers were required to train workers by December 1, 2013 on the new label elements and Safety Data Sheets format.
 
2.     By June 1, 2016, employers are required to update alternative workplace labeling and hazard communication programs as necessary, and provide additional employee training for newly identified physical or health hazards. 
 
What else do I need to know?
 
1.     Employers should ensure they post, in a prominent location in the workplace, the OSHA "It's the Law" poster, which can be downloaded for free in English and Spanish at www.osha.gov. 
 
2.     OSHA also imposes record-keeping requirements on employers.
 
3.     OSHA can impose penalties for noncompliance.

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