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OSHA Revisions to the Hazard Communication Standard

Reference Number: MTAS-1892
Tennessee Code Annotated
Reviewed Date: April 25, 2017
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In the March 2012 edition of the Federal Register (77 FR 17574), OSHA published its revisions to the OSHA Hazard Communication Standard (HCS). The revisions align OSHA requirements with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals, commonly called the GHS. To provide time for compliance, OSHA established a phase in program for the requirements over a period of several years. The transition period ended June 1, 2016.

The revisions improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals. Two significant changes in the standard require the use of new labeling elements and a standardized format for Safety Data Sheets (SDSs), formerly known as Material Safety Data Sheets (MSDSs). The new label elements and SDS requirements improve worker understanding of the hazards associated with the chemicals in their workplace. The standard applies to all chemicals known to be present in the workplace in such a manner that employees may be exposed under normal conditions or in a foreseeable emergency. Employers have a duty to provide adequate training on these changes to the communication standards at no cost to all employees (full-time, part-time or temporary).

Employers may conduct the training in-house or may contract with someone knowledgeable on the revised OSHA hazard communication standard to conduct the training. The employer must provide training in a manner that is understandable by each employee, which means the employer must consider and accommodate limitations such as language, vocabulary, and literacy. Employers are still required to do annual training on hazard communication (HAZCOM) in addition to these new requirements.

Employers must train their workers on the new label elements and the SDS format. This training is necessary to protect themselves from chemical hazards in the workplace. It is critical that employees understand the new label and SDS formats. Training is also required at the time an employee is assigned to work with any hazardous chemical and whenever a new hazard is introduced into the employees work area.

The list below contains the minimum required topics the training.

  • Training on label elements including:
    • Product identifier 
    • Signal word(s)
    • Pictogram(s)
    • Hazard statement(s)
    • Precautionary statement(s)
    • How an employee might use the labels in the workplace
    • General understanding of how the elements work together on a label
    • Where the employee can get all the information on the hazards of the chemical(s)
  • Training on the format of the SDS
    • How to obtain and use the hazard information on an SDS
    • Differences between MSDSs and SDSs and how to utilize the MSDS

Employers must also include volunteer firefighters for purpose of the training and must train all employees even if the employees are illiterate or have learning disabilities. Employers must also measure the effectiveness of their training by verbal recall and evaluate training through employee interviews.

The employer must provide annual training and maintain records of the training that include:

  • Identification of those trained
  • Date of the training
  • Brief description (e.g., symptoms of CO poisoning, H2SO4 emergency procedures, etc.)

The training records must be maintained for the period of employment + 5 years and must identify the following:

  • Identity of the employee trained
  • Date(s) of training
  • Brief description of the training

The employer must maintain SDS for as long as the chemical is used or stored. You must maintain the chemical list for 30 years

Because TN is a federally approved "state-plan" the TN Occupational Safety and Health Act (TOSH Act) adopted the federal OSHA standards but some of the provisions of the TN Hazardous Chemical Right to Know Act are still in effect. Tennessee OSHA (TOSHA) has a video presentation that an agency can download and use for training on the revisions and the GHS. The person who conducts the training should be familiar with OSHA's Hazard Communication Standard. The video is available at https://www.youtube.com/watch?v=F41FCs2V5uE.

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