OSHA requires training for all your employees by December 1, 2013. The requirement affects all your employees with potential exposure to hazardous chemicals and has to do with recent changes to OSHA’s Hazard Communication Standard (HCS).OSHA's training requirement is just the first step toward ensuring that employees not only know about hazardous chemicals but can also understand the information related to hazardous chemicals. OSHA has adopted the Globally Harmonized System to meet this objective.
Globally Harmonized System (GHS)
Part of the best practice for the HCS includes “The United Nations Globally Harmonized System of Classification and Labelling of Chemicals, Revision 3.” Although this mouthful of a name sounds a bit like a ‘70s soft drink commercial (teaching the world to sing), the Globally Harmonized System will help protect employees worldwide from chemical hazards by making hazard communication more understandable.
One of the GHS’s features includes pictograms (simplified pictures) to communicate the health or physical hazard (or both) of each of the hundreds of thousands of hazardous chemicals used. The GHS refers to these hazards with pictograms. These GHS pictograms are white, diamond-shaped icons outlined in red with black illustrations in the center. The 8 pictograms that OSHA has adopted include:
- Health Hazard
- Exclamation Mark
- Exploding Bomb
- Gas Cylinder
- Flame Over Circle
- Skull and Crossbone
The actual pictograms and detailed GHS information are covered in the Steri-Safe Preferred and Select GHS Safety Meeting, available now.
MSDSs Move to SDSs
Remember Material Safety Data Sheets, also known as MSDSs? These sheets communicated information about chemical hazards in the workplace. MSDSs will be replaced by Safety Data Sheets, or SDSs. An SDS includes hazard information in a new, uniformly structured format.
Information and Training on Hazardous Chemicals
As an employer who doesn’t produce or import chemicals, OSHA requires you to establish a written Hazard Communication Program that includes, among other requirements, information about the new labels and SDS, and then accurately communicate this information to your employees. According to 29 CFR 1910.1200 Hazard Communication:
"Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets."
In your HCS training, you must also include information about how your employees can protect themselves from exposure to chemicals found in their work environment. Appropriate emergency measures also must be part of the training you offer.
Moreover, your training must include an explanation of the hazard labels received on shipped containers. You are not responsible for creating the SDS. This is the manufacturer’s obligation. Additionally, manufacturers have a deadline of June 1, 2015 to update their container labels with the new labeling system.
In summary, healthcare office managers must know the following:
OSHA requires updated Hazard Communication Standard (HCS) training
Deadline for HCS training is December 1, 2013
Employee training must include:
New SDS and label format awareness
Workplace procedures and protective measures that can safeguard employees from chemical exposure in your employees’ work environment
Emergency procedures — in case of accidental chemical exposure
Steri-Safe Select and Steri-Safe Preferred customers can go to MyStericycle.com to access:
Globally Harmonized System (GHS) Safety Meeting (available now)
Hazard Communication Standard (HCS) Training (available now)