The Occupational Safety and Health Association (OSHA) is proposing to align the current Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Below are answers to some of the most common questions according to OSHAs Web site.

What does the current HCS state?
The current HCS requires that chemical manufacturers and importers evaluate the chemicals they produce or import. They also must provide hazard information to downstream employers and workers by putting labels on containers and preparing safety data sheets. Under the current HCS all employers must have a hazard communication program for exposed workers, including container labels, safety data sheets and training.

What will the new HCS provisions include?
The provisions will adopt a standardized approach to hazard classification, labels and safety data sheets. This will include a single set of harmonized criteria for classifying chemicals and labels including signal words, pictograms as well as hazard and precautionary statements. In addition, safety data sheets would have standardized format.

How it was decided?
This system was agreed on at an international level by governments, industry and labor, and adopted by the United Nations in 2002 with a goal of 2008 for implementation.

How will modifying the current HCS be an improvement?
Modifying and streamlining the HCS will ensure improved quality and more consistency; enhance worker comprehension, resulting in appropriate handling and use of chemicals; and eliminate the current system of multiple labels and safety data sheets for other countries, creating additional work for chemical manufacturers and those involved in international trade.

Who will this affect?
An estimated over 40 million workers and five million facilities will be affected as a result of this change.

Why is the cross-over beneficial?
If the revisions are to pass, the new rule could potentially prevent 43 fatalities and 585 injuries and illnesses annually and a reduction of $266 million in safety and health risks. OSHA estimates additional annualized benefits of $585 million a year from cost reductions and productivity improvements attributable to the proposed revisions. In total, OSHA estimates that the proposed revisions will provide net annualized savings of $754 million a year.

What are the major proposed changes?

• Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
• Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram and hazard statement for each hazard class and category. Precautionary statements must also be provided.
• Safety Data Sheets: Will now have a specified 16-section format.
• Information and training: The GHS does not address training. However, the proposed HCS will require that workers are trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safety data sheets.

How can I make my comments known?
The public can submit comments by mail, facsimile or electronically. OSHA welcomes questions on all relevant issues of this proposed rulemaking including hazard classification, economic impacts and specifically impacts on small businesses, other affected standards, outreach and finally alternative approaches. Public comments are due by December 8, 2009.