Now that OSHA has revised the Hazard Communication Standard to align with GHS, the question many employers, chemical manufacturers, distributors and end users have is: Will I be able to continue to use my NFPA and HMIS labeling systems?
The answer is yes . . . But they may cause confusion. The question becomes not whether you can, but whether you should.
First, let’s look at the old standard’s requirements. In the old standard (pre-HazCom 2012), labels (and labeltext) on shipped containers and workplace labels were performance based. That means OSHA didn’t say exactly what had to appear on the labels. Instead, it said what effect the labels had to achieve; OSHA’s goal: to successfully transmit hazard information to the end user.
Many companies adopted either the NFPA or HMIS system for workplace labeling. Both systems are simple and effective. A criteria was established to identify the health, physical, reactivity and personal protective equipment that was required. A numerical system from 0-4 identified the hazard from lowest (0) to worst (4).
Simple right? Well it was until HazCom 2012 adopted the GHS recommendations and added health and physical criteria and categories. Now, a chemical that was previously a number “1” meaning it had a low hazard, is now a “4” meaning it has a low hazard.
What’s an employer to do? If you have used a number based Continue Reading…