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How HazCom2012 Affects Your Business
In 2012, OSHA enacted a major revision to its Hazard Communication Standard (29 CFR 1910.1200). The new standard, called HazCom2012, affects all sign shops, screen print shops and digital print shops regardless of company size. No one is exempt. Even if you employ fewer than 10 employees, you still must comply with the new regulations.
The new Hazard Communication Standard (HCS) is designed to familiarize workers with the dangers associated with any hazardous chemicals that they work with and to provide them with the necessary training, so they can safely handle these chemicals. By training workers to understand the new safety sheets and new hazard symbols and warnings, employees can help their employers comply with the new requirements and fast-approaching deadlines.
The new standard also complies with the United Nations Global Harmonization System of Classification and Labeling of Chemicals (GHS). Don’t worry…we have not yet ceded our sovereignty to the UN. While the GHS is not in itself a regulation, it provides a framework for agencies, such as OSHA, to implement elements of the GHS within their system.
The key elements of the Hazard Communication Standard include keeping a file of the appropriate safety data sheets, developing a written hazard program, maintaining a chemical inventory, proper use of hazard labels and employee training. This is nothing new. What is new are some major changes to the HCS. These changes include new criteria for classifying hazardous materials, new labeling for all hazardous materials, and a new 16-part format for Safety Data Sheets (SDS), which were previously called Material Safety Data Sheets (MSDS).
The new labeling, required under the provisions of HazCom2012, consists of several essential components, including a signal word; a pictogram; and any applicable hazard statement for each hazardous component as well as any pertinent precautionary statements. All of these key elements must be present on the label in the format compliant with the GHS labeling system. Providing consistent labeling, whether chemicals are shipped domestically or internationally, will help end any confusion regarding hazards.
By June 1, 2015 manufacturers, distributors and importers are responsible for ensuring that all containers that contain chemical substances must be labeled with a GHS compliant label. The labeling requirement also includes secondary containers. What that means is that if fill or repackage a container with a hazardous chemical from another container that was received from a manufacturer, you must label the refilled or secondary container with a GHS label, if used by more than one person or on more than one shift.
By June 1, 2015 chemical manufacturers must reclassify their chemicals using the GHS criteria. By this date, the manufacturers must also provide the end users with safety data sheets (SDS) in the new 16-part format. If containers of hazardous chemicals are not labeled with the new GHS labels, the employer is responsible to contact the supplier to obtain the compliant labels.
The new safety data sheets provide comprehensive information about the hazards of a substance used in the shop. Their purpose is to provide employers with the information that enables them to train their employees to safely use hazardous chemicals in the workplace. The SDS also provides information on managing dangerous materials for emergency response and medical professionals.
Even if a manufacturer only provides an SDS as a courtesy, their documents must conform to the new format. OSHA requires manufacturers to deliver the safety bulletins either before or with the shipment of hazardous chemicals. In the past, manufacturers and distributors had the latitude to provide MSDSs in various formats. The new standardized format is designed to make the information more accessible to the downstream user.
Under OSHA’s Hazard Communication Standard (HCS), maintaining safety bulletins is a key responsibility of an employer. Shops must organize any existing MSDS or the new SDS bulletins in a binder or better yet in an electronic file. While OSHA does not require employers to retain these bulletins for 30 years following use of the products, an employer must maintain a record of the specific chemical substances to which their employees were exposed to for 30 years. An employer is also required to document when and where these chemicals were used. As an alternative to this detailed record keeping, OSHA recognizes that maintaining MSDS bulletins for that period satisfies any of their requirements.
The Looming December 1st Deadline
The first important deadline for compliance with the provisions of the new HazCom2012 standard is December 1, 2013. This is just the first of several deadlines that will affect printers and sign makers, as well as suppliers to the graphics market.
By December 1st of this year, if you are an employer, you must have completed training of your workers on the new GHS labeling system and the new safety data sheets. Expect OSHA to assiduously check for training compliance. The purpose of the training is to provide workers with the information that they need to decipher the safety labels and safety bulletins, so they recognize any hazards and take the appropriate actions.
To ensure employees understand how to protect themselves from chemical hazards, your training program must cover the following topics:
- What information is required on new labels? Why is this information important? How should employees use this information?
- Product Identifier: How are hazardous chemicals identified on the new labels? (These include chemical name, code number or batch number.)
- Signal Word: What words are required to alert employees of potential chemical hazards? (Only two signal words are acceptable: Danger and Warning.) How are “Danger” and “Warning” defined? (Danger is used for the more severe hazards. Warning is used for less severe hazards.)
- Pictogram: What pictograms are required in the new labeling program? How are these pictograms related to corresponding hazard classes? (Eight specific OSHA pictograms are required to identify hazard categories.)
- Hazard Statements and Precautionary Statements: What information do hazard statements and precautionary statements provide employees? (Hazard statements describe the nature of a chemical hazard. Precautionary statements provide recommendations for handling and storage of hazardous chemicals to minimize prevent health risks resulting from exposure.)
- How does the information on the new labeling relate to the information in the SDS bulletins?
- What are employers obliged to cover in HazCom2012 training?
- What information is provided in the new 16 section SDS bulletins? (The new SDS format contains information about exposure limits, engineering controls and personal protective equipment.)
To help you comply with the new training requirements, SGIA has developed its Right-to-Know Training Program. The program is now available on DVD with both English and Spanish language options, and provides an introduction to the potential hazards of chemical products found in a typical screen or digital facility. For more information, visit the SGIA website at http://www.sgia.org/govt/ga_RightToKnow.cfm .
By June 1, 2016, all employers must be fully compliant with HazCom2012. That means that all of you employees must be trained; you must be using the GHS compliant labels; and you must maintain your MSDS and SDS documentation.
The time to start is now. If you do not have a person in your company responsible for hazard communication, assign someone. Make it part of his or her job to understand the requirements of the HazCom2012, you should assign one. He or she should also be responsible for conducting a physical inventory of all chemicals in your shop. The inventory of hazardous chemicals should note any current hazard classification. After checking that you have a current safety bulletin in your file for each chemical, your designated safety person, should contact suppliers and request missing and updated bulletins. You should also safely dispose of any chemicals which are no longer needed. Finally, make sure that all hazardous materials are properly labeled by June 1st of 2016.
To help you satisfy the training requirements before the December 1st 2013 deadline, OSHA has published several documents:
Training Requirements Document: https://www.osha.gov/Publications/OSHA3642.pdf
Information on Labels & Pictograms: https://www.osha.gov/Publications/OSHA3636.pdf
Information on Safety Data Sheets: https://www.osha.gov/Publications/OSHA3514.pdf