Although many organizations are still wrestling with the operational implications of the adoption of GHS in OSHA 2012, OSHA has recently signaled that the agency may consider more HazCom changes in the next round of rulemaking.
Are HazCom Changes in the Works?
OSHA HazCom is based on Revision 3 of the UN GHS purple book. In a meeting in November, OSHA representatives stated that they would consider all changes to the criteria through Revision 7 (currently under revision but slated for release soon). So, what does that mean for us?
Potential changes (variances in Revision 3 through Revision 6) could include the following:
- New Hazard Class – Desensitized Explosives
- New Hazard Categories
- Flammable Gas Hazard Class – Categories A and B
- Flammable Aerosols Hazard Class –changed to ‘Aerosols’ which will continue to include flammable aerosols and adds a new Category 3 for non-flammable aerosols
- Clarification to criteria in the Skin Corrosion/Irritation and Eye Damage/Irritation Hazard Classes.
- Pyrophoric Gas classification that aligns with UN GHS criteria
- Updated Precautionary Statements (and accompanying label requirements)
- Updates to Appendix D for Sections 2, 5, 7 and 9 of the SDS
In the November 2016 meeting, OSHA requested feedback regarding the applicability, relevance and impact of potential changes. Not without concern for those affected by change, OSHA leaders were clear in their intention to obtain a pulse from industry stakeholders and the impact of changing the Hazard Communication Standard.
When Can We Expect HazCom Changes?
OSHA’s next step is to publish a Notice of Proposed Rulemaking (NPRM) and solicit feedback from the industry (you can follow the progress of the update to the HCS). The regulatory agenda for this rule provides October 2017 in the timetable as the date for the NPRM. Although we cannot know how long the process will take or exactly when to expect the NPRM, the EHS industry can evaluate the use of best practices and compliance solutions, enlist the support of chemical data management partners such as SiteHawk to help implement regulatory updates in current systems and brace for new rules in the coming months.
As you navigate the changes of global regulatory agencies, check out SiteHawk’s Environmental Hesalth & Safety Resources to find a collection of helpful links to relevant websites in the EHS industry. The evolution of GHS continues and SiteHawk is your partner in the journey.