OSHA has undergone several changes lately in their administrative departments.  There are several vacant positions and regulation updates seem to be slowly making their way to the public.   The Hazard Communication standard changed to incorporate the Globally  Harmonized System (GHS), and no new updates have come down the pipeline, as of July 2017.

Will There Be Additional Changes to Hazard Communication?

OSHA officials seem to think that changes to the standard are not expected to happen anytime soon.  But the Deputy Director of OSHA’s Directorate of Standards thinks it would be a good idea to update HazCom to the most current GHS Revision (Revision 5 was released in 2015 and Revision 7 will be released in 2017).  The most recent OSHA revision to HazCom was in 2012 in an attempt to align with international classifications.  But experts say that the alignment is not complete.  International companies have to create multiple documents to do work out of the country.

Navigating Hazard Communication Compliance

Since the final deadline for implementing the 2012 HazCom/GHS updates, OSHA has been citing companies for hazard communication noncompliance at a substantial rate.   In fact, HazCom was the 2nd most cited violation in 2016.  Aligning with GHS has created headaches and noncompliance issues because of downstream delivery issues.

Employers who receive incorrect Safety Data Sheets, or do not have one at all, should have a process in place to obtain one.  Experts have recommended switching suppliers if their current supplier cannot provide a compliant Safety Data Sheet.  Keep in mind that if you do come across this issue and have both old and new formatted Safety Data Sheets, make sure employees are trained for both formats.   OSHA does permit you to use the old format SDS if the chemical manufacturer has closed down.

As a reminder, SRP recommends that employees receive Annual Refresher Safety Training to include Hazard Communication/GHS.

Source: Safety Compliance Alert Newsletter, July 17,2017

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