Back in 2011 we alerted you that OSHA was in process of promulgating a new HazCom standard. It is finally a done deal. After much wailing and gnashing of teeth, OSHA finally has a new regulation to unveil to US businesses. They have dubbed this standard HazCom 2012.
If your email inbox is like mine, you’re getting bombarded with promises for Webinars and Seminars on how the standard will affect you.
ECS has begun the review of the standard in its final form and will be offering a free seminar to our clients in the summer of 2012. It is our plan to create a training DVD which clients may choose to purchase in order to train their employees on the new rules. Stay tuned for a date to be announced in May.
In the meantime, you can be working on updating your chemical inventory lists and archiving old MSDS for chemicals you no longer use on-site. This will help you as you start determining which MSDS have been updated with the new Safety Data Sheet (SDS) format and which ones you still have yet to receive from the manufacturer.
This may be a good opportunity to consider if it is time to break down & get an MSDS service. 3E & other systems will solicit MSDS (soon SDS) in the new format for you, flag the ones missing and do all the legwork to update the info in a searchable format. 3E in one of their packages has GHS label templates included.
You may already have some of the new format SDS in your binders now. Some chemical manufacturers (especially the large ones like DuPont and Exxon) have already created their SDS in the new format. If that’s the case, you’ll note that the layout is different, is consistent for all SDS and contains some new information. When ECS offers our free seminar in the summer, we will review the changes to the SDS so that EHS managers understand how to use this new resource.
Labeling is another area that will change substantially with the new rule. There are new pictograms and warning words not previously used in the US. We will review those in the seminar as well. The good news is that we have until June of 2016 to utilize the current labeling system.
All of these changes will involve retraining existing and new employees to the new standard. The good news is that we have until December 1, 2013 to conduct updated training. It is ECS’ plan to offer our clients a very reasonably priced training DVD with hand-outs and trainer resources.
Another area of concern is your company’s Hazard Communication Program. This program will require updating to the new standard by 6/1/2016.
In the meantime, we encourage you to read about the new standard, attend webinars and seminars to increase your comfort level with the new standard. ECS is here to assist you in implementing this updated standard and will be offering support materials in the near future.