National Clothesline
National Clothesline
OSHA changing HazCom standard
It’s out with the old and in with the new as OSHA adopts new elements for its Hazard Communication Standard to bring it in line with the United Nations' global chemical labeling system.
Phasing out will be the familiar Material Safety Data Sheets, replaced by new Safety Data Sheets which will convey much of the same information but in a different format. Also new are a set of pictograms and “signal” words that indicate the particular hazards of a product.
One thing that does not change is the requirement of training for employees so that they understand what the various parts of the hazard communication program are communicating. In fact, even though the new system won’t be fully phased in until June, 2016, OSHA wants workers trained now — December 1 of this year specifically is the official deadline.
OSHA said early training is necessary because many chemical manufacturers are already producing labels and safety data sheets that are compliant with the new global system and it wants to ensure that when employees begin to see them, they will understand how to use them and access the information effectively.
OSHA estimates that more than
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five million workplaces in the United States will be affected. Those are the workplaces where employees — a total of approximately 43 million — could be exposed to hazardous chemicals. That, of course, includes drycleaning plants.
Employees need to undergo training and sign-off on having done so in order to keep record that can be shown OSHA in the event of an inspection. While OSHA inspections of drycleaners are infrequent — 119 in 2012 and 129 through October of this year — shortcomings or a complete of absence of a hazard communication program is the second most frequently cited violation when inspections do occur. Fines can run from $1,000 on up.
As new Safety Data Sheets come in, cleaners will need to integrate them into their hazard communication files. Old MSDS’s should be kept on file, too, until they are supplanted by one of the newer ones. Operating under a dual system during the phase in could be confusing, but OSHA believes that ultimately the improved consistency of the labels and Safety Data Sheets will make for easier training of employees.
Employee training, according to OSHA, must cover the following areas:
• The type of information an employee would expect to see on the new labels. This includes how the hazardous chemical is identified, such as the chemical name, code number or batch number.
• Signal words used to indicate the severity of hazard. There are only two signal words, “Danger” for more sever hazards and “Warning” for less severe hazards.
• Pictograms: OSHA has designated pictograms (shown in the chart at left) which must be in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame.
• Training on the format of the standardized 16-section Safety Data Sheets. The SDS sections cover hazard identification, composition and information on ingredients, first-aid measures, fire fighting measures, accidental release measures, handling and storage, exposure controls and personal protection, physical and chemical properties, stability and reactivity, and information on toxicology, ecology, disposal, transportation, regulatory requirements.
• Hazard statements that describe the nature of the hazard of a chemical, such as “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.” All applicable hazard statements must appear on the label.
• Precautionary statements that describe recommended measures to minimize or prevent adverse effects exposure or improper storage or handling.
• How an employee might use the labels in the workplace to, for example, ensure proper storage of chemicals or quickly locate information on first aid.
To help cleaners satisfy the training requirement, the National Cleaners Association has an on-line program developed by Mike Tatch, a safety engineer and consultant, that should make the training relatively easy.
The program was designed specifically for the drycleaning industry and is available in English, Spanish and Korean. Information is available on the NCA web site, www.nca-i.com.
Last month the Rocky Mountain Fabricare Association offered two seminars for members on the new requirements and how to conduct training.
Henry W. D. Parker of Safety and Environmental Compliance Consultants led those seminars and can provide training services to other drycleaners. His web site is www.complyhere.com.
Complete details on OSHA’s Hazard Communication standard, including information on the new requirements and a guide to training, are also available on OSHA’s web site at www.osha.gov/dsg/hazcom/index.html.

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