Deadlines to comply with Washington’s new hazard communication rules differ from OSHA

The Occupational Safety and Health Administration (OSHA) recently revised the Hazard Communication Standard in order to improve comprehension of hazard information found on product labels. Safety Data Sheets (SDSs) will replace the current Material Safety Data Sheets (MSDSs), which will more effectively prevent injuries and make it safer for workers to do their jobs.

The federal deadline for compliance to train employees is December 1, 2013. In Washington, however, the WA Industrial Safety and Health Act (WISHA), doesn’t require compliance to begin until June 1, 2014. WISHA supersedes OSHA for all but federal workers.

But that doesn’t mean you should wait to prepare.

Major changes to the hazard communication standard include the following four areas:

  1. Hazard Classification: For each chemical, the chemical manufacturer or importer must determine the hazard classes, and where appropriate, the category of each class that applies to the chemical being classified. Employers are not required to classify chemicals unless they choose not to rely on the manufacturer’s classification.
  2. Labels: The information on labels will become more standardized to increase employee comprehension of the potential hazards and precautions. New labels will feature hazard pictograms, a signal word such as “danger,” hazard and precautionary statements and both a product and supplier identifier.
  3. Safety Data Sheets: The new standard will have a specified 16-section format and replace what is currently known as a Material Safety Data Sheet (MSDS).
  4. Information and training: Employers are required to train workers by June 1, 2014 on the new label elements and SDS format to facilitate recognition and understanding.

Written Hazard Communication Plan
Employers must develop, implement, and maintain a written hazard communication program which describes how the criteria for labels and other forms of warning, safety data sheets, and employee information and training will be met, and which includes the following:

  1. A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas);
  2. The methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas;
  3. The employer may rely on an existing hazard communication program to comply with these requirements, provided that it meets the criteria established in this section; and
  4. The employer must make the written hazard communication program available, upon request, to employees.

Employee training
Employers must include in their employee training the minimum following elements:

  1. Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
  2. The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;
  3. The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used;
  4. The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information; and
  5. Document when employee training is conducted and obtain signatures verifying comprehension of the updated information on labeling and hazard communication.

Save the new SDSs that arrive with new procurement orders and replace MSDSs with the new SDSs for your recordkeeping. If you maintain a hardcopy notebook, discard the old labels and insert the new ones. If using an electronic database, delete the old and save the new labels. Finally, communicate with your suppliers and vendors that your practice expects the new SDSs with future orders.

Secondary labeling
Employers are not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer.

The following are exempted from the new requirements:

  • Hazardous waste that is regulated by the Environmental Protection Agency;
  • Any food, food additive, color additive, drug, cosmetic, or medical or veterinary device or product or any such product that already has labeling requirements by the FDA or USDA; and
  • Any drug when it is in solid, final form for direct administration to the patient (e.g. tablets or pills); this exemption does not apply if pills are used as an ingredient in making another product of formula, nor does it apply to capsules, liquids, gels or powders.

Important Dates
June 1, 2014 Train employees on the safety data sheet (SDS) format and new label elements.

June 1, 2015 Chemical manufacturers and importers are required to comply with new requirements.

Dec. 1, 2015 Distributors must ship products with new labels.

June 1, 2016 Employers must update labels on "workplace" containers and train employees on newly identified hazards. Update the Hazard Communication Program, as needed.

Important Links
Current hazard communication rules - WA Dept of L&I

Hazard Communication and the Globally Harmonized System (GHS) – WA Dept of L&I

FAQs about the Global Harmonization System – WA Dept of L&I

Hazard Communication/GHS Rules Update e-Lesson – WA Dept of L&I

SDS 101 – Reading and Using Safety Data Sheets - AVMA

Sample Written Hazard Communication Program











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