It’s been four years since the OSHA 1910 General Industry Hazard Communication standard was passed into law. It was without question the biggest change OSHA has made to an individual standard in decades. For all the changes made, perhaps the one that is the most overlooked is the “Labels and other forms of warning” rule spelled out in Section 1200 Paragraph (f).
It may now be time to circle back and look at the specifics of what this Paragraph obligates the employer to do label wise in their work place. And when I say work place, I specifically mean “Workplace labeling” as in (f) (6) (i) and (ii).
If you have assumed that you are required to change all your work place or secondary “Haz Com” labeling to the new GHS (Global Harmonized System) format you may want to revisit this part of the standard. Cutting to the bottom line here, you as the employer have the choice to use the GHS labeling as defined in (i)….or as stated in (ii) you may use another labeling system/program. This option means that you can still use the old HMIS or NFPA system in your work place. You’re good using an old labeling system, as long as you understand, that you must convey the chemical hazard(s) of your chemical system to your employees that is comparable to the hazards conveyed if using the new GHS system.
Here’s another point to remember, and that is that all hazardous chemicals now being received have the GHS formatted label on their package, drum, bag or primary container. So this means that your Haz Com training should include GHS as well whatever secondary labeling system you decide to use.
For further guidance on this topic, go to https://www.osha.gov/Publications/OSHA3636.pdf
Start reading closely on the bottom of page 4 and where it continues to page 5.
Please call me at (540-337-1213 Ext 19204) or contact me at firstname.lastname@example.org if you have a question.
John Sutton, CSP and CHMM