Theatre Design & Technology - Spring 2018 - Public - 49

he purpose of the OSHA revised standard is to conform to the United
Nations Globally Harmonized System of Classification and Labeling
of Chemicals (GHS) as well as provide more useful information about
chemicals and their hazards. Dec. 1, 2013, was the first compliance date
in the revised Hazard Communication Standard, referred to as the 2012 HCS
(29 CFR 1910.1200, Subpart Z). The window to implement this revised standard
lasted from Dec. 1, 2013 to June 1, 2016.
"This update to the Hazard Communication Standard (HCS) will provide a
common and coherent approach to classifying chemicals and communicating
hazard information on labels and safety
data sheets [....] This update will also
help reduce trade barriers and result in
productivity improvements for American
businesses that regularly handle, store,
and use hazardous chemicals while providing cost savings for American businesses that periodically update safety
data sheets and labels for chemicals covered under the hazard communication
standard." (OSHA)
While not the only changes, the two
most notable and visible changes are
the revised and renamed MSDS, now
named Safety Data Sheets (SDS), and
the introduction of revised label content
including warning pictograms. The new
labels should improve comprehensibility
and facilitate compliance.
On June 1, 2015, the Hazard Communication Standard required the use of
pictograms on labels to alert users of the
chemical hazards to which users may be
exposed. The only exception to the use of
these Hazard Communication Standard
pictograms is if a pictogram required by
the Department of Transportation under
Title 49 of the Code of Federal Regulations appears on a shipped container,
the 2012 HCS pictogram specified for
the same hazard shall not appear (29
CFR1910.1200 appendix C 2.3.3). Published in the Federal Register in March
2012 (77: 17574-17896), the requirements were to be phased in from Dec. 1,
2013, thru June 1, 2016.

There are three significant changes:
1. Standardized labeling elements
2. Standardized format for Safety Data
Sheets (SDS), which replaces the Material Safety Data Sheets (MSDS)
3. Use of pictograms to communicate
specific hazard information
The Dec. 1, 2013, deadline required
the following minimal training on label
elements to be completed:
* Product Identifier is placed on both
the label and the SDS.
* Signal Words are "Danger" and "Warning." Only one signal word may be on
the label. If the product has more than
one hazard, and at least one hazard
should have the "Danger" signal word
on the label, then "Danger" should be
the only signal word used on the label.
* Pictograms ensure the employee will
see the appropriate pictogram on the label. If there are multiple hazard classes,

multiple pictograms will be present.
See chart 1 or 29CFR1910.1200 Appendix C for the correct format of the
pictograms.
* Hazard Statement or Statements
describe the hazard or hazards of the
chemical. An example could be: Causes
severe respiratory distress. All of the
chemicals hazards must appear on the
label.
* Precautionary statements refer to recommended procedures to prevent or
minimize exposure to the chemical(s)
and to prevent adverse effects from
the exposure or improper storage of
the product. An example might be: Do
not store at temperatures over 110° F
(43.3° C).
* Name, address and phone number of
the chemical manufacturer, importer, or
distributor.
* Format of the standardized 16 section

Effective Completion Date

Requirement(s)

Who

December 1, 2013

Train employees on the new label elements and
SDS format.

Employers

June 1, 2015*
Dec. 1, 2015

Comply with all modified provisions of this final
rule, except:
Distributors may ship products labeled by manufacturers under the old system until Dec. 1, 2015.

Chemical manufacturers, importers,
distributors, and
employers

June 1, 2016

Update alternative workplace labeling and hazard communication program as necessary, and
provide additional employee training for newly
identified physical or health hazards.

Employers

Transition Period

Comply with either 29 CFR 1910.1200 (this final
standard), or the current standard, or both.

All chemical manufacturers, importers, distributors,
and employers

* This date coincides with the European Union implementation date for classification of mixtures.
Source: OSHA

SPRING 2018

THEATRE DESIGN & TECHNOLOGY

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