Commercial building and plant facility owners endeavor to stay current on hazard communication standards. The HCS legislation was passed in 1994 under CFR 1910.1200. A Revised Hazard Communication Standard passed in 2012 to agree with international requirements. The HCS originally was a standard that protected workers in facilities with potential chemical hazards.
HCS 1994 and HCS 2012 Update
It is important to note the changes contained in HCS 1994 with those in HCS 2012. For example, HCS 1994 stated the issue was to:
"…ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training." In HCS 2012, chemicals produced or imported are "evaluated," HCS 2012 states these are "classified.” MSDSs are referred to as "safety data sheets" in HCS 2012. Much of the purpose of HCS 2012 grants federal rather than state authority over hazardous materials. The reason for this may lie with the growth in international trade and to create a more uniform international method of classifying hazardous materials rather than on domestic, state-by-state legislation.
How the Revised HCS Affects Employer-to-Employee Safety Communication
Since the passage of the HCS in 1994, plant managers have maintained safety information for employees in their facilities. Much of the safety precautions for producing and handling of chemical materials outlined in HCS 1994 remain in HCS 2012, including:
- All labels of incoming and outgoing containers of hazardous chemicals must be properly labeled and the labels may not be damaged or defaced.
- Employers are required to make Material Safety Data Sheets (MSDS) available to all employees on each work shift.
- A standard hazard communication program plan and training should also be provided by facility managers.
Within the year 2016, full implementation of the "United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS)" must be in place according to OSHA regulations.
To maintain compliance, managers may need to review prior practices and training programs and provide employees with information on these revisions. In addition, facility managers will be required to follow the GHS format for standard safety data sheets. The information contained on the newly formatted GHS safety data sheets should conform to the basic elements contained in universal labeling and safety data sheets. You may even find that much of the additional paperwork required in triplicate forms for international shipping of hazardous materials will no longer be needed, which can expedite the transportation of hazardous chemicals without unnecessary delays.
Other Issues to Review Regarding the HCS
In addition to the classification, labeling and handling of hazardous chemicals, facility managers also need to review the variables regarding classifications relating to federal EPA regulations outlined within HCS 2012. For example, goods that are potential health hazards, flammables, corrosives and others. It is important to also review the HCS 2012 revisions that define goods no longer considered to be potentially hazardous.
Facility managers should review the terms and definitions in the Consumer Product Safety Act found in 15 U.S.C. 2051 et seq. You’ll also need to detail how a hazardous substance is used in workplace as outlined in the Federal Hazardous Substances Act found in 15 U.S.C. 1261 et seq. or the purpose for which it may be intended by the chemical manufacturer or importer. The facility manager must also provide information about "use and results as well as duration and frequency of exposure."
It’s also a good idea to stay cognizant of the liability that could be incurred if the Revised Hazardous Communication Standard is not fully understood by management and employees. In the final wrap departments, employees should receive complete HAZCOM training with regard to use of specific containers for shipping hazardous goods, the safest and most allowable method of transport and also the specific types of hazardous labels applied before shipping or internal facility use.
With the increased responsibilities and duties of facility managers, the Revised Hazardous Communication Standard adds regulatory experience to facility management. Although the job of creating the operation's Hazardous Materials Management Plan may be outsourced to professional regulatory consultants, the plan should also be fully reviewed and accessible to all employees. In addition, a regular program of hazardous materials training can avoid serious injury and resulting liability.
Tim Brooks is the Director of Marketing for Atlantic Training, a safety training company offering over 10,000 titles in DVD, streaming and LMS formats. He handles coordination with outside partners as well as new projects and products.
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