HAZCOM 2012
More Hazard Communication Issues

An inquiry was made by the American Coatings Association, which they asked OSHA to clearly outline the import of materials and the export of materials in sealed containers for the Hazard Communication Standard (HCS). The Occupational Safety & Health Administration (OSHA) responded with a Letter of Interpretation (LOI) on November 23rd, 2015 which further clarified the responsibilities of US companies when importing or exporting materials that require attention under the 29 CFR 1910.1200

In regard to import OSHA’s guidance in the LOI states the responsibility falls on the importers to assure compliant labeling when the material becomes under their control. Once in their control, importers must follow the requirements of 29 CFR 1910.1200(b)(4) where applicable. Importers must also assure compliance with HCS 2012 prior to shipping within the United States. In this LOI, OSHA encourages the review of their CPL-02-02-079 Section X.F.2h compliance directive which entails information for materials packaged for shipment prior to June 1st, 2015.

OSHA’s guidance for export in this LOI for sealed containers is that if prepared for direct shipment outside the US and are inside a USDOT approved shipping container, the manufacturer can label the container for the destination country. A HCS compliant label must be affixed to the outside package or be attached to the shipping papers as well. The container would also have to be labeled according the appropriate regulation for Continue Reading…

OSHA Hazard Communication Website Gets a Facelift

As I get older and more wrinkles, crow’s feet and age spots appear on my face, I consider some sort of plastic surgery like a facelift. According to the dictionary, a facelift is a procedure carried out to improve the appearance of someone or something.  A little nip and tuck, tightening and smoothing could go a long way in removing some of my signs of aging. So, how does my desire to look younger have anything to do with OSHA? To put it simply, OSHA’s website on Hazard Communication got a facelift.

US Department of Labor - OSHA Hazard Communication Website Screenshot
Click to enlarge

OSHA announced the update to the Hazard Communication website in the November 2nd QuickTakes newsletter under the Educational Resources section. To see the full newsletter, click here.

The new look actually makes the site easier to maneuver through as there are now drop-down tabs that can be used for faster searching for needed information. A quick review of each tab is as follows:

  • Safety Data Sheets: This tab includes the Safety Data Sheets QuikCard™ in both HTML and PDF formats along with the OSHA SDS Brief regarding Safety Data Sheets that incorporates Appendix D of the HazCom2012 regulation.
  • Labeling: On this tab the setup is very similar to that of the Safety Data Sheets. An additional link is to a QuickCard™ of a comparison between NFPA and OSHA labels.
  • Pictograms: Here again are the same features as the Continue Reading…
We’re Ready When OSHA Is!

ICC is ready for GHS

In January 2011, OSHA proposed that in August of this year, they would publish the final rule to align the current Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The more recent DOL Spring semi-annual regulatory agenda released in June revisits the scheduling of the release of the HCS revision to an unspecified date in September of this year. September has now come and gone, and we are still without a final rule from OSHA.

This leads to the question of “If not now, then when?”. It is probably a safe assumption that OSHA’s lack of implementation of GHS to date will be a major topic of discussion at the October 1st – 5th Society for Chemical Hazard Communication (SCHC) fall conference in Washington, DC. Many health and safety professionals, myself included, will be impatiently waiting for word of a revised deadline.

At ICC, we have been preparing for the new requirements so that we are ready when OSHA is. Updates and products related to GHS can be found on our website at: http://www.thecompliancecenter.com/regulations/ghs.htm

GHS Implementation – A Quick Guide for International Suppliers

Slowly but surely, the Globally Harmonized System (GHS) is becoming "the way things are done" for hazard communication around the world. Many countries have already implemented internal versions of the GHS. Others, such as the United States and Canada, are on the verge of introducing their own. How does one keep track of who’s doing what? Here’s a list of some of the most vital resources for those concerned about hazard communication worldwide.

  • The UN "Purple Book" (Globally Harmonized System of Classification and Labelling of Chemicals). This document is the basis of the GHS around the world. It is developed by the UN Subcommittee of Experts on the Globally Harmonized System (UNSCEGHS). The GHS Subcommittee has been tasked with producing biennial updates to this document; currently, the book is in the third revision (2009-2010). You can obtain a downloadable PDF version of the Purple Book at unece.org. The download is free and you do not have to register. Hard copies are available through our online store (US | Canada).
  • UN Guidance documents. Although the Purple Book is, at first glance, written in reasonably clear language, some of the sections are very technical. The UN has provided some guidance documents that can help readers understand the rules in more general terms. These guides include: