As you no doubt already know, The Occupational Safety and Health Administration (OSHA) has revised its Hazard Communication Standard (HazCom) effective July 19, 2024. The updated Hazard Communication standard (29 CFR Part 1910) concerns classification, labeling and Safety Data Sheet criteria by updating them up to the UN GHS 7th revision.
The Globally Harmonized System (GHS) is an international framework developed by the United Nations to standardize the classification and labeling of chemicals by using pictograms, signal words, hazard and precautionary statements to classify and communicate the hazardous characteristics of chemicals. The Occupational Safety and Health Organization (OSHA) met the GHS standard in 2012. On May 24, 2024 OSHA updated the standard (via 29 CFR Part 1910) to align with the UN’s 7th revision and parts of the 8th.
These changes encompass twelve years of incremental updates that, in many cases, have already been in force in Europe for many years; and in Canada, from January 2023. If you are an international manufacturer and already have Trace One SDS Authoring Environment, Health and Safety (EHS) Compliance Software, you will already have many of these updates in the system. But if you do not have an updated, automated way to handle these changes, you have a long road ahead. If your company produces basic chemicals, specialty compounds, fertilizers, detergents, and solvents, you need to get busy.
OSHA has published a short Q and A on changes to classifications, SDSs and labels. These include:
Labels will include new or updated hazards, updated guidance, and precautionary statements.
The updated standard went into effect on July 19, 2024, but there are phased compliance deadlines for chemical manufacturers, importers and distributors:
The burden on manufacturers can be lessened when an automated system is in place to ingest your suppliers’ SDSs and run a query on all your products impacted by the new standards. Downstream, a good system will also author, generate and print your labeling changes, enabling you to assess the costs involved, plan for production, and ensure you meet all deadlines.
Some chemicals you produce will need reclassification according to the expanded or newly added or updated classifications, for example, flammable gases or desensitized explosives. You will need to share updated SDSs and labels with downstream users and train employees on these new requirements.
The first step is to review your current raw materials suppliers. They should have updated SDSs with the correct information from the updated regulations (for chemical and some personal care manufacturers, the updated classification can be found in Section 2). Because many mixture manufacturers create base mixtures for a wide variety of industries you will obviously ensure all 16 sections of suppliers’ SDSs have the appropriate information.
If prior non-hazardous substances are now deemed hazardous, you need to reclassify and relabel these products going forward. All of your chemical substances must be reviewed for the new regulations.
The most troublesome part of the new regulations is the end-user classification requirements. For example, if a salon worker is using hairspray made from your mixture, you now must keep them in mind. If they are working with a flat iron at 450-degrees Fahrenheit and are spraying a client’s hair, will the hairspray release formaldehyde, a known irritant? Will build up of product on the flat iron create an unsafe coating that could impact the skin?
Some manufacturers deliver thousands of products to the U.S. market with literally hundreds of thousands of end uses. It is up to mixture manufacturers to do their due diligence and testing on the hazardous ramifications for these users. In practice, that means a lot of research to find and label every product in your portfolio. If you have your suppliers’ SDSs stored in a good EHS software platform, the appropriate designations will be there for other markets, like the EU and Canada.
Recent regulatory updates address labeling for chemical containers, particularly small containers under 100 ml. While labels on these containers must still be more comprehensive and easier to read, there are exemptions to simplify labeling:
Larger containers, like drums or bulk mixtures, will continue to follow the full, comprehensive labeling requirements:
The 16-section SDS will provide detailed information about chemicals in a standardized format, with clarity, while trade secret can be claimed in order to provide essential hazard information while using updated concentration ranges. You must provide the updated versions to all customers and distributors.
The new requirements, particularly regarding chemical labeling and SDSs, create a brand-new project you need to approach as proactively as possible. You will likely need a project manager and a review process to make sure all your suppliers provide the SDSs in time. You will then need to ensure that all the labeling will be ready before the appropriate compliance date.
If you already have an automated SDS and label authoring EHS system, you are in a better position to align your actions. The mixtures involved will be there in the system, so all you must do is run reports, plan your supplier SDS project, and plan for the new labels for the products. Yes, there may be hundreds of substances involved. But the deadlines are looming.
Let’s say you’re using legacy Enterprise Resource Planning (ERP) systems to handle your HazCom workflows. You’ll need a software platform that works with these enterprise systems to handle these tasks. Ideally, your software can run on batch after hours. You can identify which mixtures are impacted without taking time out of your employees’ normal jobs.
Your SDS and labeling system should already have back-end updates because they’re based in the cloud. So employees, again, can concentrate on value-driven activities instead of administration and upgrades. The system can run GHS regulatory calculations, SDS and label composition, certificate generation, and document distribution–all with a few clicks.
It’s crucial to have an authoring tool that also does the following:
The system should also calculate “N.O.S.” shipping names for all these UN numbers, including the data in Table A of Chapter 3.2 of the ADR for the compilation of the SDS, including Tunnel Restriction Codes and special provisions.
You can generate exposure scenarios with a step-by-step, user-friendly interface that makes it easy to insert relevant information in predefined fields. The exposure scenario tool should be based on the Cefic ESCom package and include the ESCom phrase catalog of over 1,600 phrases, including translations in all EU languages. step-by-step, user-friendly interface that makes it easy to insert relevant information in predefined fields. The exposure scenario tool should be based on the Cefic ESCom package and include the ESCom phrase catalog of over 1,600 phrases, including translations in all EU languages.
Your tool should compile an accurate database that keeps track of each SDS: what has been sent, when, and to whom, including when the SDS was last opened. Connected to your ERP systems, it will have the most current list of contacts, a detailed record of SDS distribution, and the last date of purchase. Finding and getting the new SDSs from suppliers that are compliant with the new regulations can be done faster and more accurately–and you can forget about combing through emails to get a status of that crucial step.
Make sure the labeling process in your software includes a way to customize or use fixed text fields and generate GHS and ADR pictograms with all the correct regulatory sentences needed. It also needs to easily generate barcode 1D and all of the new or updated labeling requirements.
The SDS/label software you choose must have real-time access. This allows you to target the new regulatory classifications for each mixture and keep Quality Assurance aligned and engaged for new and existing products. Cloud-based functionality aligned with ERP integration keeps your system updated when you add new products under these regulations and, of course, for the original updates needed to stay compliant with the new GHS. It should:
There’s a lot to do to make sure you can generate comprehensive and legible labels, detailed 16-section Safety Data Sheets (SDSs), and ultimately meet the compliance deadlines in January and in July. With the right EHS management software, HazCom compliance can be done on time and without causing headaches, hours of overtime, data entry and second-guessing. If you’d like to learn more about how you can better identify impacted mixtures, run regulatory calculations on your portfolio, and generate updated SDSs and labels, contact us.
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