4.4 Hazard Communication & GHS SDS Management (OSHA 1910.1200)

Hazard Communication (OSHA 1910.1200)

Often called the "Right-to-Know" law, OSHA's Hazard Communication Standard (HCS) ensures that employees are informed about the identities and hazards of the chemicals they are exposed to in their workplaces. In 2012, OSHA significantly updated the HCS to align with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This alignment brought standardized classification criteria, uniform labels, and a consistent format for Safety Data Sheets (SDSs), replacing the older, highly variable Material Safety Data Sheets (MSDSs). As an OHST, managing the HazCom program is often a primary responsibility.

The Core Elements of a HazCom Program

A comprehensive Hazard Communication program must be written and include the following key components:

1. Written Program: A document detailing how the facility will comply with the standard, including how labels, SDSs, and training will be managed.
2. Chemical Inventory: A comprehensive list of all hazardous chemicals present in the workplace, cross-referenced to the SDS file.
3. Labels and Other Forms of Warning: Ensuring all containers of hazardous chemicals are properly labeled.
4. Safety Data Sheets (SDSs): Maintaining accessible, up-to-date SDSs for every chemical on the inventory.
5. Employee Training: Training workers on the hazards of the chemicals in their work area and how to read labels and SDSs. Training must occur at the time of initial assignment and whenever a new chemical hazard is introduced.

GHS Labeling Requirements

Under the GHS-aligned standard, chemical manufacturers and importers must provide a label that includes six specific elements. Employers must ensure workplace containers are also labeled effectively.

The six required elements on a primary shipped container label are:

1. Product Identifier: The name or number used for the hazardous chemical on the SDS and chemical inventory.
2. Supplier Identification: The name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.
3. Precautionary Statements: Phrases that describe recommended measures to minimize or prevent adverse effects resulting from exposure (e.g., "Wear protective gloves/eye protection," "Keep away from heat/sparks").
4. Hazard Statements: Standardized phrases assigned to a hazard class and category that describe the nature of the hazard(s) of a chemical (e.g., "Causes severe skin burns and eye damage," "Highly flammable liquid and vapor").
5. Signal Word: A single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The GHS uses only two signal words:
   • Danger: Used for the more severe hazards.
   • Warning: Used for the less severe hazards.
6. Pictograms: Standardized graphical symbols used to communicate specific information about the hazards of a chemical. There are nine GHS pictograms, each featuring a black hazard symbol on a white background with a red diamond border. Examples include the Flame (flammables), Skull and Crossbones (acute toxicity), and Health Hazard (carcinogens, respiratory sensitizers).

Secondary Container Labeling

When a chemical is transferred from its original shipped container into a secondary container (e.g., a spray bottle or a smaller transfer jug), that secondary container must be labeled. Employers have flexibility here; they can replicate the primary shipped label information, or they can use alternative systems like the NFPA 704 diamond or HMIS system, provided that the alternative system, combined with training, conveys the specific physical and health hazards of the chemical.

Exception: Secondary containers do not require a label if they are intended only for the immediate use of the employee who performs the transfer (e.g., filling a beaker for a single experiment and disposing of the remainder before the shift ends).

The 16-Section Safety Data Sheet (SDS)

The alignment with GHS mandated a strict, 16-section format for all SDSs. This standardization is critical for emergency responders and employees to quickly locate necessary information without hunting through variably formatted documents.

The OHST must be familiar with the contents of all 16 sections, but several are particularly critical for workplace safety management:

Ensuring that the chemical inventory is accurate, that all containers are properly labeled, and that SDSs are readily accessible (either physically in binders or electronically via a reliable system with backup) are daily requirements for maintaining compliance with 1910.1200.