Changes to the OSHA Hazard Communication Standard: Are You Ready?
The Occupational Safety and Health Administration (OSHA) began enforcing the Hazard Communication Standard (HCS) in 1983 in response to concerns over injuries and deaths due to workplace exposure to hazardous chemicals. The standard was modified in 1994, but resulted in few, if any, changes for the average dental practice. During this past year, new regulations became effective with elements being phased in through 2016 (Table 1).
These regulations require action on the part of chemical manufacturers and employers.1 Major changes in the HCS include adoption of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS), which replaces the material safety data sheet (MSDS) with the more standardized safety data sheet (SDS).
Along with these changes, GHS includes universally accepted means of communicating the hazards associated with chemicals.2 By December 1, 2013, all employers were required to have provided updated training to employees who may encounter hazardous materials in the workplace.
The basic elements of the HCS have not changed: All hazardous materials must still be identified and labeled, and training should be provided to employees regarding the safe handling of the specific materials. Common hazardous materials in dentistry include disinfectants, isopropyl and ethyl alcohols, sodium hypochlorite, etchant, and resins. Anything that the manufacturer has identified with a hazard warning statement on the label (eg, harmful if swallowed, avoid contact with eyes) is included in the workplace hazard communication program.
Globally Harmonized System
The need for GHS came about because many countries were using different schemes of hazard classification for the same chemicals. The increase in international trade created a scenario in which it would be possible for a manufacturer in one country to sell product to a distributor in another without the distributor having full awareness of the material’s hazardous nature.1 This, in turn, could have resulted in the end user, the employee, not being cognizant of the need for personal protective attire or other safety measures when using the chemical.
The GHS uses a combination of signal words, hazard statements, and standardized pictograms to communicate hazards associated with a specific chemical. The pictograms are a new element and use internationally agreed-upon images to denote specific hazards (Figure 1). Chemicals began to appear using these pictograms this year, and the requirement must be fully implemented by June 1, 2015. It is not required that employers update labels on containers, even if they are labeled under the previous HCS. Therefore, if an office is storing items that do not have the new pictograms when the deadline for labeling requirements arrives, it is still acceptable to leave the labels as they are.
Labeling and Safety Data Sheets
Primary responsibility for labeling of chemicals lies with the manufacturer or distributor. The manufacturer must provide specific information on the label, including the manufacturer’s name, address, and telephone number; product name or identifier; signal words (such as warning or hazards); hazard statements; precautionary statements; and pictograms.3 Employers do not need to replace manufacturers’ labels but must ensure the labels are maintained in a legible condition and that the information regarding the hazards and directions for use do not fade, get washed off, or get removed in any way. Employers may use alternative labeling if they wish, but they must ensure that they provide either all of the information from the manufacturer’s label or the product identifier and words, pictures, symbols, or a combination thereof, which, in combination with other information immediately available to employees, provide specific information regarding the hazards of the chemicals. This may be a sensible option in major industrial settings. But for most dental offices, simply maintaining the original label on all products containing hazardous chemicals should be the easiest and most reasonable solution.
Some employers choose to use alternative rating systems such as the National Fire Protection Association diamonds, which use color-coded diamonds and a numerical rating system to provide information about the hazards of chemical substances. Under the revised HCS, it is still acceptable to do this as long as the employees have immediate access to the specific hazard information. Employers using alternative labeling must also ensure that the employees receive training regarding the hazards of the chemicals in use. The one exception to the labeling requirement is when a hazardous chemical is transferred from a labeled container to a portable container intended for immediate use by the employee who performs the transfer. In this case, no labels are required for the portable container.
Previous versions of the HCS required an MSDS on file for each hazardous substance, but did not specify the format of the MSDS. This inconsistency presents a risk that an employee who has had an exposure to a hazardous chemical might not be able to quickly find the information needed to determine the appropriate type of first aid, or that the required personal protective equipment might be overlooked. The revised standard includes the use of an SDS using a specified format that requires the use of standardized section headers. The SDS contains 16 sections that must appear in the required order, even if no information is contained within certain sections.4 Those section headers would still appear but would have no information listed. Only sections 1 through 11 are enforceable by OSHA because sections 12 through 16 focus on ecologic, disposal, transportation, and regulatory information that is enforced by other agencies, such as the Environmental Protection Agency and the Department of Transportation. In addition, these sections are concerned with requirements that only pertain to the manufacturer, distributor, or transporter and not the employer or employee using the substances.
Training Requirements
OSHA identified specific areas of required training regarding the revised HCS.5 Because the main change affecting workers was the new SDS format and the new label elements, the training centered on those two areas. It was assumed some transition period would be needed as old labels and the MSDS format are phased out and new labels and the SDS format are phased in. It was before this transition began that the training should have occurred. OSHA had identified December 1, 2013 as the final deadline by which employers must have provided training to all employees who have exposure to hazardous materials in the workplace. This date was critical because these SDSs and new labels were already being used on products.
The training should have had an explanation of the following:
1. Product identifier: How a hazardous chemical is identified (eg, chemical name, product name).
2. Signal word: Indicates the severity of the hazard associated with a chemical. “Danger” is used to indicate a more severe hazard. “Warning” indicates a less severe hazard.
3. Pictogram: The eight OSHA pictograms used to label hazardous materials. These must be in the shape of a square set at a point (Figure 1) and include a black hazard symbol on white background with a red frame.
4. Hazard statement(s): These are words describing the nature of the hazard(s) and the degree of hazard. An example would be “causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.”
5. Precautionary statement(s): This is a phrase that describes a measure to minimize or prevent adverse effects of exposure to a hazardous chemical or effects of improper storage or handling of chemicals.
6. Name, address, and phone number of the chemical manufacturer, distributor, or importer: Inform employees that this is a required element of the label on all hazardous materials.
7. Safety data sheets: Explain the new SDS and the type of information found in the standardized 16-section format.
8. Use of labels: Explain how information on the label can be used to:
9. Ensure proper storage of chemicals.
Quickly locate information on first aid.
Understand that where a chemical has multiple hazards the pictograms are used to identify each of those hazards.
Conclusions
There are some significant changes to the HCS that will affect every dental office and clinic. Because the HCS must be specific to each workplace, a single training course, such as a Webinar or continuing education course, cannot meet all of the requirements for employee training. Employees need to be familiar with the hazardous materials they will encounter during the course of their work and should review the safety measures listed on each SDS for personal protective attire, storage, and handling of the materials.
Under HCS requirements, employers must continue to keep an inventory of hazardous materials and maintain an SDS for each item in that dental office’s inventory. The SDS file or binder cannot be kept in an area that is not accessible to employees, such as a locked office or locked file cabinet drawer. Employees must review the information on the respective SDS before working with the material containing the hazardous chemical. If the manufacturer or distributor does not provide an SDS, the employer must request that one be provided. Many distributors and manufacturers provide safety data sheets (or material safety data sheets while the safety data sheets are being phased in) in downloadable Internet formats.
While it is true that the employer has the responsibility to see that the HCS is properly implemented and training has been provided to all employees with exposure to hazardous materials, certain elements can be assigned to other team members. Often, a dental assistant or office manager will maintain the hazardous materials inventory and SDS library and may be the best person to conduct the training of other employees.
About the Author
Eve Cuny, MS
Associate Professor, Dental Practice
Director, Environmental Health and Safety
University of the Pacific
Arthur A. Dugoni School of Dentistry
San Francisco, California
References
1. Ta GC, Jonai H, Mokhtar BM, Peterson PJ. Model for the implementation of the globally harmonized system of classification and labelling of chemicals (GHS): lessons learned from Japan. J Occup Health. 2009;51(6):526-530.
2. Winder C, Azzi R, Wagner D. The development of the globally harmonized system (GHS) of classification and labelling of hazardous chemicals. J Hazard Mater. 2005;125(1-3):29-44.
3. U.S. Department of Labor. Hazard Communication Standard: Labels and Pictograms. OSHA Brief. DSG BR-3636. February 2013. www.osha.gov/Publications/OSHA3636.pdf. Accessed May 31, 2013.
4. McLaughlin SB. Turn the page. Preparing for the new hazard communication standard. Health Facil Manage. 2012;25(12):41-43
5. U.S. Department of Labor. December 1st, 2013 Training Requirements for the Revised Hazard Communication Standard. OSHA Fact Sheet. February 2013. DSG FS-3652. www.osha.gov/Publications/OSHA3642.pdf. Accessed June 4, 2013.
