OSHA Requests Comments on Change in HAZCOM Standard

osha-logoOSHA is proposing to modify its existing Hazard Communication Standard (HCS) to conform with the United Nations’ (UN) Globally  Harmonized System of Classification and Labeling of Chemicals (GHS). OSHA has made a preliminary determination that the proposed modifications will improve the quality and consistency of information provided to employers and employees regarding chemical hazards and associated protective measures. The Agency anticipates this improved information will enhance the effectiveness of the HCS in ensuring that employees are apprised of the chemical hazards to which they may be exposed, and in reducing the incidence of chemical-related occupational illnesses and injuries.

The proposed modifications to the standard include revised criteria for classification of chemical hazards; revised labeling provisions
that include requirements for use of standardized signal words, pictograms, hazard statements, and precautionary statements; a
specified format for safety data sheets; and related revisions to definitions of terms used in the standard, requirements for employee
training on labels and safety data sheets. OSHA is also proposing to modify provisions of a number of other standards, including standards for flammable and combustible liquids, process safety management, and most substance-specific health standards, to ensure consistency with the modified HCS requirements.

For more information on sending comments pertaining to the changes, visit HERE

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2 comments to OSHA Requests Comments on Change in HAZCOM Standard

  • OSHA needs to fix their own HAZCOM standard before global harmonization. Many aspects of GHS are fine concerning consumer protection, pesticides, and transportation yet communicating and managing the hazards in the industrial manufactruing sector is weak.

    For example, there is no provision in the current OSHA HAZCOM standard in addressing physical hazards that midstream users are exposed to in the life cycle where the raw material has changed from a seemingly harmless product into one that evolves into a potentially explosive atmosphere with combustible dust.

    An excerpt from the HAZCOM proposed rule states this issue succinctly:

    “That is, chemical manufacturers and importers tend to have greater knowledge and scientific expertise with respect to the composition of the chemicals they make or import. See 48 FR 53306, 53322.”

    “Therefore, they are usually in the best position to assess the inherent hazards associated with them. Id. However, it is the downstream users and their employees who tend to have
    the best information about the means and methods of exposure, and are therefore usually in the best position to
    determine the risk arising from the use of the chemical in their workplaces. See 48 FR 53295–96, 53307; 59 FR 6132.”

    From what I can gather from the above, downstream users must have their combustible dust tested for ignition sensitivity and explosion severity in providing supplemental information to the initial MSDS.

  • John,

    I tend to agree with you on OSHA’s weakness from the HAZCOM standpoint. In addition to the example you pointed out (i.e. 2 raw materials create a more hazardous material), consider their past stances on products such as icynene where only the final product was subject to scrutiny – the people exposed to the precursors where afforded little protection (check out some their recent interpretation letters).

    Combustible dust is most likely only going to grow in size. It will be interesting to see where we with this issue in 15 years.


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