Starting the conversation: OSHA mulls update to HazCom Standard

James Lee held up a capsule about the size of a pharmaceutical pill to a room full of OSHA staff and safety professionals.

The capsule, created by Loveland, CO-based Hach Co., is used by municipalities worldwide and researchers to test chlorine levels in water. The capsule was designed to be small to minimize potential safety and health issues for workers who use them.

However, a big problem exists, said Lee, a senior compliance analyst with Hach. The pill has a minuscule surface, which makes it challenging to include the labeling required by OSHA’s Hazard Communication Standard (1910.1200) and the Globally Harmonized System of Classification and Labeling of Chemicals, or GHS.

“It took a lot of time putting a small label onto this. I don’t even know if you can read it,” Lee said. “We were able to put in one pictogram. We had hundreds of employees last year sitting in a cafeteria labeling these things manually because we could not find a printer to do it automatically.

“We’re asking OSHA to consider having more flexibility. It may be that OSHA was not aware of what we were running into. We’re running into this issue because the current guidance from OSHA is not workable. As of right now, we are having an extremely hard time complying with the current HazCom [standard] and the guidance from OSHA.”

Lee was participating in the agency’s informal discussion about the Hazard Communication Standard on Nov. 16 in Washington. During the nearly three-hour meeting, OSHA sought feedback from stakeholders about topics that the agency should consider as part of its next revision of the standard.

As for when the next revision will occur, nobody can say for sure – particularly with a change in administration approaching. But OSHA officials want to start the conversation as they look to update the standard to align it more closely with GHS.

OSHA’s most recent revision to the Hazard Communication Standard occurred in 2012. The agency promoted the revision by declaring on its website: “The standard that gave workers the right to know, now gives them the right to understand.” The revision also provided “a common and coherent approach to classifying chemicals and communicating hazard information on labels and Safety Data Sheets.”

Read more at SafetyandHealthMagazine.com