OSHA HCS 2012 (GHS)
OSHA has substantially changed the rules and regulations related to the Hazard Communications Standard. This change is to align with the United Nations' Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. The new OSHA standard is HCS 2012 – Hazard Communications Standard 2012.
OSHA's compliance to the new standard has four deadlines:
- December 1, 2013 – All employees must be trained on the new Label Elements and SDS format.
- June 1, 2015 – All manufacturers and suppliers must ship products with the new Label Elements and SDS's.
- December 15, 2015 – All Distributors must ship products that have HCS 2012 (GHS) compliant labels
- June 1, 2016 – All employers shall, as necessary, update any "alternative" workplace labeling, update the hazard communication program, and provide any additional employee training for newly identified physical or health hazards
OSHA HCS 2012 (GHS) New Elements Training (3.3 MB) reviews the new GHS Elements to meet the December 1, 2013 training deadline. This is ideal for facility's who have already performed their annual HazCom Training.
The following offer the standard chemical Hazard Communications combined with the new HCS 2012 (GHS) elements.
Hazard Communications Training with HCS 2012 (GHS) covers the basic hazard communications standard with the new GHS elements integrated.
Supervisor Hazard Communications Training with GHS (3.68 MB) reviews the basic hazard communications standard with the new GHS elements, and adds information that is specific to a supervisor.
Sample Documents: SDS's, Product Labels, and Secondary Labels
Here are some examples of the new GHS 2012 requirements - one is a generic SDS, while the other examples are the GHS Compliant SDS and labels for Pro-Link's Blitz or Extra Duty Bowl Cleaner.
ISSA and OSHA have many materials available (usually for a fee) to help manufacturers and distributors learn about the changes, and tips for implementation. Here's the links for a few key items to make it easy for you to find.
OSHA Requirements on Training Records
OSHA's requirement for recordkeeping for training sessions vary from regulation to regulation. In some cases, OSHA sets a record retention time or specifies requirements for the contents of training records, but this is not always the case. The HazCom standard does not specify how training records are to be maintained or for how long.
Documentation, or certification of training, is required on these standards:
- Lockout/Tagout, 29 CFR 1910.147(c)(7)(iv)
- Process Safety Management, 29 CFR 1910.119(g)(3)
- Hazardous Waste Operations (HAZWOPER), 29 CFR 1910.120(p)(8)(iii)(C)
- Personal Protective Equipment, 29 CFR 1910.132(f)(4)
- Respiratory Protection, 29 CFR 1910.134(m), which does not specifically use the word "training," but refers to "written information regarding medical evaluations, fit testing, and the respirator program."
- Permit-Required Confined Spaces, 29 CFR 1910.146(g)(4)
- Powered Industrial Trucks, 29 CFR 1910.178(l)(6)
By far, the best policy is to document all formal safety training for each of your employees, regardless of whether or not it's required, it's just good practice. You can also document additional information not required by OSHA. For example, it might be useful to keep track of the following safety training data:
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Past training on the same safety topic
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Content summary
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Safety orientation dates for new employees and orientation program content
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Future training schedule
We also created a YouTube video that plays the power point for you with a narrator. Click here to play.