By Shawna Hays
Risk Management Customer Service Supervisor

Recent regulatory changes to the labeling of chemicals within the United States have a huge impact on all organizations.  The differences between a Hazardous Material Program, Hazard Communication Program, and the Globally Harmonized System have been widely publicized as employer OSHA requirements in recent years. All of these requirements are essential to the safety and wellbeing of employees. Employers who have a firm grasp of the differences and requirements of these programs are not only protecting their employees or volunteer members, but are also protecting themselves from potentially crippling OSHA fines in the future.

A Hazardous Material Program, or HazMat Program, may be what organizations are most familiar with. HazMat Programs are environmental regulations governing the storage, handling, treatment, and/or disposal of hazardous materials used or produced in facilities. Many emergency responders train on and specialize in the containment and cleanup of chemical spills. Training and response is largely based on National Fire Protection Standards (NFPA 472) and other OSHA regulations, such as the updates to a Globally Harmonized System (GHS).

Not to be confused with a HazMat Program, OSHA requires all organizations to maintain a Hazard Communication Program. Hazard Communication Programs, often referred to as HazComm or “Right to Know,” ensures that employees or members have access to information on the chemicals they use at work. The HazComm standard is the communication of chemical hazards to employees or members in order protect them. Organizations are required to educate employees and members on the chemicals they may come in contact with and how to protect themselves. They must also supply appropriate Personal Protective Equipment (PPE) and train employees and members in how to use the PPE properly. A written HazComm plan, detailing the organizations training, chemical labeling, chemical listings, etc. is also required as part of any Hazard Communication Program.

Impacting an organization’s HazComm and HazMat Programs is the United States recent transition approach to a Globally Harmonized System (GHS). GHS is the international approach to hazard communication of chemicals. It provides agreed criterion for classification of chemical hazards and a standardized approach to labeling elements. In the United States, Safety Data Sheet (SDS) will replace what were once known as Material Safety Data Sheets (MSDS). The GHS establishes a standardized 16-section format for SDS’s to provide a consistent sequence for presentation of information to SDS users. Items of primary interest to exposed employees and emergency responders are presented at the beginning of the document, while more technical information is presented in later sections. HazComm programs and plans should be revised to include elements of the GHS, including the transition from MSDS to SDS. Work still needs to be done to fully understand how GHS might impact HazMat Programs of emergency responders, but understanding GHS and it’s approach to labeling chemicals is the first step in the process.

Emergency Service Organizations, along with all other employers in the United States, were required to provide training to all members or employees by December 1, 2013, and will be required to be fully compliant with the GHS standard by June 1, 2016. While the details from OSHA of what is considered compliant regarding training is still largely foggy, we can provide the following recommendations and resources:

• E-Learning Course: Hazardous Communication: The New Standard Introduction to GHS; Covers what HazComm is and how GHS impacts it.
• E-Learning Course: GHS: The Globally Harmonized System of Classification and Labeling of Chemicals; Covers training required for the new GHS.
• E-Learning Course: Hazardous Communication Plan Development; Covers the elements of a Hazardous Communication Plan.
• Sample HazComm Policy and HazComm Plan template
• OSHA Requirements Interpretation Checklist

For more information regarding HazComm or our E-Learning courses, visit our Risk Management page here or call our Risk Management Customer Service team at 800-822-3747 Ext. 176.