OSHA revised
HazCom standard in March 2012 with training to be the starting point of
scheduled compliances. OSHA issued technical guidelines in February 2016 for
classification of chemicals. The new guidelines call for use of pictograms,
revised product labels and new format SDS, all of them contained in a lengthy
document running to 432 pages. The guidelines apply to manufacturers and
importers of hazardous chemicals and employers using such products in
workplaces.
The original
HazCom standard is complex and amendments make it even more so. Hazardous
nature of a chemical is determined by scientific tests and the hazard class
defined just how hazardous it is from the perspective of physical or health.
The hazard class has further subdivisions of hazard category according to toxicity
and flammability of chemicals. There are four categories. The hierarchy can be
confusing, especially when existing MSDS must be updated to SDS and this may
necessitate reclassification of a product into the appropriate section. Labels
too must reflect the change and provide the right information in the form of
signal words, text and pictogram. SDS and labels by themselves are of little
use unless workers can learn to interpret them and implement guidelines or
follow instructions. This means worker training is imperative to the success of
the hazard communication program. Assistance for compliance and training for Hazard
Communication Standard by ICSDS proves invaluable for
manufacturers/importers mired in the complex maze of hazard class and category
distinctions.
What is complex
for the layman is not so for experts at ICSDS. They understand the intricacies
of the guidance and the multiple appendixes that must also be referred to in
the classification of a product and preparation of SDS and labels. The task
would be easy if OSHA had a ready to use list from which one can pick the
appropriate class and category. ICSDS experts rely on their knowledge of
chemicals and draw from other authoritative sources to arive at the right
classification/categorization. It must also be kept in mind that there are
other agencies involved. For instance, the American Conference of Governmental
Industrial Hygienists has a list of threshold limit values of carcinogenic
substances.
Though deadlines
for compliance have passed and OSHA is lenient, the situation may not continue
and non-compliance could result in fines. Speedy updates or preparation of new
SDS and labels by ICSDS helps manufacturers avoid this likelihood. At the same
time, ICSDS also offers general training on OSHA hazard communication standard
29CFR1910.1200 to bring workers and employees to speed in latest labeling
methodologies, pictograms, interpretations and guidelines on safe handling. The
concise yet comprehensive course endows workers with full knowledge about 5 key
elements of HazCom, their rights under the standard, capability to identify
label symbols and other information.
There is no
getting away from compliance and it is not possible for staff or employees of a
manufacturer or importer to take on the task of SDS/labels or even training
given the complexity and chances of errors. Engaging ICSDS, on the other hand,
makes it an easy and quick process.
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