7.3 Hazard Communication (HazCom), Safety Data Sheets (SDS) & Chemical Safety

7.3 Hazard Communication (HazCom), Safety Data Sheets (SDS) & Chemical Safety

Quick Summary: The OSHA Hazard Communication Standard (HazCom), codified in 29 CFR 1910.1200, was updated to align with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Known as the transition from the "Right-to-Know" to the "Right-to-Understand," HazCom requires employers to classify chemical hazards and communicate risks to employees. Occupational health nurses must oversee HazCom compliance by verifying barrier-free electronic or physical Safety Data Sheet (SDS) access, interpreting 16-section SDS documents (focusing on Sections 4 and 8 for clinical care and PPE controls), enforcing GHS container labeling, and verifying secondary container compliance.

OSHA Hazard Communication Standard (29 CFR 1910.1200) & GHS Alignment

Chemicals are ubiquitous in industrial, healthcare, and manufacturing environments. The OSHA Hazard Communication Standard (HCS) ensures that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees.

The Shift from Right-to-Know to Right-to-Understand

Historically, the 1983 HazCom standard focused on worker "Right-to-Know." However, inconsistent hazard definitions and variable Material Safety Data Sheet (MSDS) formats created confusion. In 2012 (and updated under 2024 OSHA rule revisions), OSHA aligned 29 CFR 1910.1200 with the GHS framework:

• Standardized Hazard Classification: Chemicals are classified using specific criteria for physical hazards (e.g., flammability, explosiveness) and health hazards (e.g., acute toxicity, carcinogenicity, skin corrosion).
• Harmonized Labeling: Uses standardized signal words, hazard statements, precautionary statements, and universal pictograms.
• Standardized 16-Section SDS: Replaced non-standard MSDSs with a uniform 16-section format.

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Core Employer HazCom Obligations

Employers using hazardous chemicals in the workplace must fulfill four mandatory operational obligations:

1. Written Hazard Communication Program:

   • Develop, implement, and maintain a written HazCom program customized to the facility.
   • Must detail how chemical container labeling, SDS management, and employee training are operationalized.
   • Must contain a complete chemical inventory listing all hazardous chemicals present, cross-referenced to SDSs.

2. Chemical Inventory & SDS Accessibility:

   • Employers must maintain a Safety Data Sheet (SDS) for every hazardous chemical in the workplace.
   • Barrier-Free Access: SDSs must be readily accessible during each work shift to employees when they are in their work areas. Electronic access (e.g., intranet portals) is permitted provided there are no password barriers, delays, or risk of system failure during power outages. OHNs must ensure paper backup or uninterruptible power supplies exist.

3. Employee Information & Training:

   • Training must be provided to employees at the time of initial assignment to a work area where hazardous chemicals are present.
   • Re-training is required whenever a new physical or health chemical hazard is introduced into their work area (e.g., introducing a carcinogen into a line previously using only mild solvents).
   • Training must cover: methods to detect chemical releases, physical and health hazards of chemicals, protective measures (engineering controls, work practices, PPE), and details of the facility HazCom program (labels and SDS interpretation).

4. Trade Secret Rules (29 CFR 1910.1200(i)):

   • Chemical manufacturers may withhold specific chemical identities or exact concentration percentages as trade secrets on SDSs.
   • Medical Emergency Exception: In a medical emergency, the manufacturer MUST immediately disclose the specific chemical identity to an occupational health nurse or physician upon request, without requiring a prior signed confidentiality agreement.

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The Standardized 16-Section Safety Data Sheet (SDS)

Every SDS follows a strict 16-section format, ensuring critical hazard and clinical information is presented predictably:

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GHS Labeling Elements & Secondary Container Rules

Core GHS Shipping Container Label Elements

All primary chemical containers shipped by manufacturers or distributors must display a GHS label containing six mandatory elements:

1. Product Identifier: Chemical name or code matching the SDS.
2. Signal Word: A single word used to indicate the relative severity of hazard:
   • "DANGER": Used for severe hazard categories (e.g., highly toxic, flammable liquids Category 1).
   • "WARNING": Used for less severe hazard categories.
3. Hazard Statements: Standardized phrases describing the nature and degree of hazard (e.g., "Fatal if swallowed," "Causes severe skin burns and eye damage").
4. Precautionary Statements: Standardized phrases recommending measures to minimize or prevent adverse effects across four categories: Prevention, Response, Storage, and Disposal.
5. Pictograms: Square red-bordered diamonds containing a black hazard symbol on a white background. OSHA enforces 8 pictograms (the 9th, Environmental, is non-mandatory):
   • Health Hazard: Carcinogen, respiratory sensitizer, reproductive toxicity, organ toxicity, germ cell mutagenicity.
   • Flame: Flammables, pyrophorics, self-heating, emits flammable gas.
   • Exclamation Mark: Irritant (skin/eye), skin sensitizer, acute toxicity (harmful), narcotic effects, respiratory tract irritant.
   • Corrosion: Skin corrosion/burns, eye damage, corrosive to metals.
   • Gas Cylinder: Gases under pressure.
   • Exploding Bomb: Explosives, self-reactives, organic peroxides.
   • Flame Over Circle: Oxidizers.
   • Skull & Crossbones: Acute toxicity (fatal or toxic).
6. Supplier Identification: Name, address, and telephone number of the manufacturer or importer.

Secondary Container Labeling & Immediate-Use Exception

When a chemical is transferred from a primary labeled container into a secondary container (e.g., squirt bottle, beaker, bucket), the secondary container MUST be labeled with either the full GHS label elements or workplace-specific labeling (e.g., NFPA 704 diamond or HMIS system indicating specific hazard warnings).

The Immediate-Use Exception (29 CFR 1910.1200(f)(8)): Secondary container labeling is NOT required if the hazardous chemical is transferred into a secondary container intended ONLY for the immediate use of the employee who performs the transfer, and the chemical remains under their exclusive control during that work shift. If the employee leaves the work area, steps away, or ends their shift, the secondary container MUST be fully labeled immediately.