OSHA Goes Global
All Employers Must Train Employees On Updated Hazard Communication Standards By December 2013
The U.S. Occupational Safety & Health Administration (OSHA) has agreed to the United Nation’s standard for a Globally Harmonized System (GHS) of classification and labeling of chemicals.
This simply means that the Material Safety Data Sheets (MSDS) for chemicals will look the same in all nations across the globe. An existing rule, called the Hazard Communication Standard (HCS), was updated to accommodate the global standardization.
The HCS has always been the rule that requires employers to provide training and chemical hazard information for their employees. The requirement of maintaining an inventory and the MSDS for chemicals found in the workplace is the most commonly-known portion of the rule. Having a safety supervisor, MSDS, monthly training and a written HCS, is the gist of the rule.
What is new is the format of the MSDS changing to the global standard and becoming known as Safety Data Sheets or SDS, which look similar to MSDS and contain the same information, but will uniformly convey that information in all languages augmented by the use of universally accepted hazard pictograms.
By December 2013, employers that have chemicals in the workplace must train employees on the updated HCS.
Make A Plan
The HCS is based on a simple concept, employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working. Identify responsible staff by designating a safety supervisor. Hazard communication is an ongoing program in the facility. In order to have a successful program, it is necessary to assign responsibility for both the initial and ongoing activities that have to be undertaken to comply with the rule.
The HCS requires a list of hazardous chemicals in the workplace as part of the written hazard communication program. The list serves as an inventory of everything for which a MSDS / SDS must be maintained. The best way to prepare a comprehensive list is to survey the workplace. Purchasing records may also help. Employers should establish purchasing procedures that result in MSDS / SDS being received before a material is used in the workplace. Check your files against the inventory of chemicals in the workplace to ensure that an MSDS / SDS exist for each potentially hazardous chemical. If any are missing, contact the supplier and request one. As chemical manufacturers convert their existing MSDS to GHS SDS format, GHS labels will accompany the new SDS. Begin using the term Hazard Communication Standard along with the more familiar MSDS.
All workplaces where employees are exposed to hazardous chemicals must have a written plan which describes how the standard will be implemented in that facility. The plan does not have to be lengthy or complicated. It is intended to be a blueprint for implementation of your program - an assurance that all aspects of the requirements have been addressed. Keep a copy of this written plan in the MSDS binder or readily available in case of an OSHA inspection.
Present the HCS to employees as this month’s safety training topic and / or have the employees review the S/P2.org module on hazard communication. Following the presentation, have each employee sign a training log. A sample log can be downloaded at http://ccar-greenlink.org/wp-content/uploads/2012/10/Employee-Safety-Training-Log1.pdf. Keep the monthly Safety training record on file (such as in a red MSDS binder) in the event of an OSHA inspection.
Employee training on hazard communication will be a key factor in the success of your organization’s implementation of GHS. The end result will be improved safety for workers via their awareness of the pictograms and other information provided on manufacturers’ GHS SDSs and labels, in particular the necessary steps to protect people and the environment when responding to a chemical hazard.
Monthly Safety Training Using S/P2
Providing a training topic each month can be a challenge, but should not be used as an excuse to be noncompliant. Encourage those employees using the S/P2 Program and those that are not such as office personnel to use the on-line program to augment the brief meeting.
Safety training should not have a beginning and an end, but represent an ongoing effort that continually promotes a safe working environment.
The S/P2 safety training is based on U.S. Department of Labor OSHA standards, which require that personnel be trained on safety and environmental regulations at the beginning of their employment, and at least annually thereafter. Completion of the S/P2 course is one great way to meet this requirement with confidence. Some basic topics to cover throughout the year includes:
• Personal protective Equipment (PPE)
• Fire Extinguisher Safety
• Spill Clean Up Procedures
• Welding & Cutting Torch Use
• Blood-borne Pathogens
• First Aid Kit
• Eye Wash
• Forklift Operation
• Lifts and Hoists
• Fire Escape Route
• Safety Awareness Signs
S/P2 is made available with an annual subscription and licensed on a “per roof” or per facility basis. The initial price of a subscription is $299 each, which allows the shop unlimited access for the 12-month period. Under this setup, new employees may be added to the system and trained immediately at no additional charge. Each employee is assigned a unique PIN to go along with the shop’s account ID and password, and the training is available 24 / 7, so each person may train at the time of day that best suits their needs.
The S/P2 program consists of three courses (Collision Safety course, Collision Pollution Prevention course, Supervisor’s course). CCAR recommends that, in addition one employee at the facility completing all three courses, all others in the shop complete the Safety and Pollution Prevention courses. All training is covered under the single annual subscription payment. Certificates of completion for all S/P2 courses are valid for one year from the date upon which the final exam is completed.
OSHA has concluded that effective management of worker safety and health protection is a decisive factor in reducing the extent and the severity of work-related injuries and illnesses. Effective management addresses all work-related hazards, whether or not they are regulated by government standards. As always, S/P2 is there to meeting your safety training needs.
Sue Schauls is an independent environmental consultant with automotive expertise. She is the Environmental & Safety Consultant for CCAR-GreenLink the EPA automotive compliance assistance center. She is the Executive Director & regulatory consultant for the Iowa Automotive Recyclers (IAR); she developed and implements the Iowa – Certified Auto Recyclers Environmental (I-CARE) Program. She contributes articles to several trade publications and is a member of ARA Technical Advisory and Certified Auto Recyclers Committees. Sue has a bachelor’s of Arts degree in Science: Environmental Planning from the University of Northern Iowa, 1996.
Get started on a compliant safety program with www.SP2.org and some simple steps:
1. Use a red three-ring binder to keep all safety training and MSDA / SDS.
2. Create a written Hazard Communication Plan using the information in this article.
3. Keep logs of monthly safety training assigned to employees such as using SP2.org modules or having monthly safety meetings.