What problems can arise when old and new hazard classifications coexist at the same site during the transition to OSHA’s 2024 HazCom final rule? How should employers manage any confusion?
Responding is Phil Molé, MPH, principal EHS expert, VelocityEHS, Chicago.
We’re in the transition period for OSHA’s 2024 HazCom final rule, which updates the HazCom standard (1910.1200) to align with the seventh revision (and parts of the eighth revision) of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals, or GHS. The final rule introduces new classification categories and modifies others. With compliance deadlines approaching, many people managing hazardous chemicals still have uncertainty.
One key concern is what to do if old and new hazard classifications coexist for the same chemical at your site during the transition. This question goes straight to the heart of purpose of the HazCom standard. Here’s what employers need to understand.
The importance of hazard classifications
Under the HazCom standard, the hazard classification by the chemical manufacturer or importer determines other critical safety information, such as the associated hazard pictogram, precautionary statement and hazard statement (P and H statements). When OSHA changes hazard classifications, it’s typically to provide users with more useful and accurate information for safely storing and using chemicals.
As an example, the final rule introduces a new category: desensitized explosives. Previously, these products were classified as explosives and labeled with the “exploding bomb” pictogram. However, desensitized explosives are treated with a stabilizing (wetting) agent, which reduces their immediate risk.
For that reason, it’s very important that end users have P and H statements explaining how to verify that stabilizing agents are in place because, without it, the product behaves like an explosive. Confusion comes with major consequences.
If these products are in your inventory, make sure employees have the new information, including the flame pictogram and updated use and storage instructions.
Managing classification confusion
Employers can take these key steps to help reduce confusion during the transition:
Manage the influx of new Safety Data Sheets and shipped container labels. As chemical manufacturers and importers reclassify their chemicals under the final rule, expect a steady churn of new SDSs and shipped container labels. If only the classification has changed, not the formulation, archive outdated documents and ensure current information is easy to access.
Use new hazard information to update your workplace HazCom practices. Once the information is more visible, use it. Know your chemical inventory well enough to identify substances affected by the final rule. Then, update your written HazCom plan, revise training and ensure secondary workplace container labels reflect the latest information. Organizations that successfully navigate this transition will be those acting on new hazard information, not just filing it away.
Get the support you need. The reality is that mixed classifications are unavoidable in the short term, but confusion doesn’t have to be. The right tools and support can make a big difference. Chemical management software can help leverage your full inventory at the ingredient level, access updated SDSs and archive old ones, and use revised information to improve workplace chemical safety.
Editor’s note: This article represents the independent views of the author and should not be considered a National Safety Council endorsement.
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Original article published by Safety+Health an NSC publication