3.2 Chemical Hazards: Hazard Communication, GHS, & SDS Management

Hazard Communication Standard (HCS)

OSHA's Hazard Communication Standard (HCS), often referred to as the "Right-to-Know" law, ensures that employers and employees are informed about the identities and hazards of chemicals in the workplace. In 2012, OSHA aligned the HCS with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This alignment transformed the standard from a "Right-to-Know" framework to a "Right-to-Understand" framework, standardizing how chemical information is conveyed.

The Written Program

The cornerstone of compliance is the written Hazard Communication Program. This site-specific document must detail how the facility will meet the standard's requirements for labels, Safety Data Sheets (SDSs), and employee training. It must also include a comprehensive, up-to-date inventory of all hazardous chemicals present on-site. If multiple employers share a worksite (e.g., construction sites), the written program must outline how they will exchange chemical hazard information to protect all workers.

GHS Labeling Requirements

Under GHS, chemical manufacturers, importers, and distributors must ensure that each container of hazardous chemicals leaving their facility is appropriately labeled. A fully compliant GHS label includes six specific elements:

1. Product Identifier: How the chemical is identified (chemical name, code number, or batch number), matching the identifier on the SDS.
2. Signal Word: A word indicating the relative severity of the hazard. GHS uses only two signal words: "Danger" (for more severe hazards) and "Warning" (for less severe hazards). Only one signal word is used on a label.
3. Hazard Statements: Standardized phrases describing the nature and degree of the hazard (e.g., "Causes severe skin burns and eye damage" or "Highly flammable liquid and vapor").
4. Precautionary Statements: Phrases describing recommended measures to minimize or prevent adverse effects from exposure, improper handling, or storage (e.g., "Keep away from heat/sparks/open flames. - No smoking").
5. Pictograms: Standardized graphical symbols that convey specific hazard information visually. GHS defines nine pictograms (e.g., flame, skull and crossbones, health hazard, corrosion).
6. Supplier Identification: The name, address, and telephone number of the manufacturer, importer, or other responsible party.

Secondary Workplace Labeling

When employers transfer chemicals from a primary container into a secondary container (e.g., a spray bottle or a smaller jug), the secondary container must be labeled. Employers can use the original GHS label information or an alternative system (such as HMIS or NFPA 704 diamonds), provided the alternative system conveys the specific physical and health hazards and is fully understood by employees through training. The only exception to secondary labeling is for portable containers intended for the immediate use of the employee who performed the transfer within that same shift.

Safety Data Sheets (SDS)

The SDS is a detailed informational document prepared by the manufacturer or importer. Under GHS, the SDS must follow a strict 16-section format, ensuring that critical information is always found in the same location, regardless of the supplier or country of origin.

The 16 Sections of an SDS

While all sections are important, safety professionals must be intimately familiar with the layout:

• Section 1: Identification - Product identifier, manufacturer contact info, and recommended use.
• Section 2: Hazard(s) Identification - All hazards regarding the chemical; required label elements.
• Section 3: Composition/Information on Ingredients - Chemical ingredients and trade secret claims.
• Section 4: First-Aid Measures - Important symptoms, effects, and necessary first-aid treatment.
• Section 5: Fire-Fighting Measures - Suitable extinguishing techniques and equipment; specific chemical hazards from fire.
• Section 6: Accidental Release Measures - Emergency procedures, protective equipment, and methods of containment/cleanup.
• Section 7: Handling and Storage - Precautions for safe handling and storage, including incompatibilities.
• Section 8: Exposure Controls/Personal Protection - OSHA PELs, ACGIH TLVs, engineering controls, and required PPE.
• Section 9: Physical and Chemical Properties - Characteristics like flash point, vapor pressure, and appearance.
• Section 10: Stability and Reactivity - Chemical stability and possibility of hazardous reactions.
• Section 11: Toxicological Information - Routes of exposure, related symptoms, and acute/chronic effects.
• Section 12: Ecological Information (Non-mandatory) - Environmental impact.
• Section 13: Disposal Considerations (Non-mandatory) - Safe disposal practices.
• Section 14: Transport Information (Non-mandatory) - Shipping guidelines.
• Section 15: Regulatory Information (Non-mandatory) - Specific safety, health, and environmental regulations.
• Section 16: Other Information - Date of preparation or last revision.

Note that OSHA does not enforce Sections 12-15, as they fall under the jurisdiction of other agencies (e.g., EPA, DOT).

Employee Training

Employers must train employees on hazardous chemicals in their work area at the time of their initial assignment and whenever a new chemical hazard is introduced. Training must cover methods to detect the presence or release of the chemical, the physical and health hazards, protective measures (including PPE and emergency procedures), and how to read and understand GHS labels and SDSs.