OSHA's Hazard Communication Standard

The Occupational Safety and Health Administration’s (OSHA) hazard communication standard (HCS) (29 CFR § 1910.1200) establishes workers’ right to know of the chemical hazards they may be exposed to in the workplace and how they can protect themselves from those hazards. Employers, such as healthcare facilities, are required to develop and execute a written plan that describes how they will implement the HCS.

Among other provisions, the plan must describe how employers will make—and keep current—an inventory of all the hazardous chemicals in the workplace and inform their employees about the hazardous chemicals the employees are exposed to by means of a written hazard communication program, labels and other forms of warning, safety data sheets (SDSs), hazard and protective measure information, and training. The HCS also requires the designation of a hazard communication program coordinator and implementation of a system to inform outside employees, such as contractors, about hazardous chemicals.

As anticipated, the HCS underwent a major revision in 2012 to be aligned with the international Globally Harmonized System of Classification and Labelling of Chemicals (GHS); the finalized rule became effective on May 25, 2012. Deadlines for compliance with the new rule vary for chemical manufacturers and importers, as well as employers. See Table 1. Important Dates to Remember for HCS Implementation.

The GHS was formally created during the 1992 United Nations Conference on the Environment and Development and is the result of international environmental and safety concerns related to the various methods used to communicate chemical hazards in different countries. While many countries have similar laws and regulations regarding this information, there are enough differences (e.g., a chemical considered flammable in one country may not be classified that way in another country) that confusion may occur. (OSHA “Hazard Communication”) The GHS provides a system for the standardization of chemical identification and hazard information to assist employers and workers in identifying the chemical, associated hazards, precautions necessary, and actions needed if exposure occurs, helping to protect workers (UN).

The GHS provides various regulatory components for the classification and labeling of hazardous chemicals but leaves it up to each country to use the criteria and provisions that are most appropriate for its regulatory authorities. (OSHA “Hazard...