Can your company "opt-out" of
the HCS/GHS updates?
The short answer to this question is "no."
While OSHA did receive comments that certain companies should be allowed to
opt-out of complying with the revised GHS portion of the HCS, other commenter’s
argued that having a multiple systems in place would undermine the
implementation of the rule. OSHA agreed that multiple rules would cause
confusion and that allowing even one company to deviate would affect other
companies. OSHA also acknowledges that small chemical companies would
incur burdens not necessarily felt by larger companies. However,
employees in the end-user workplaces deserve to have access to the same
chemical information regardless of the size of the generating company.
OSHA, therefore, determined that in order to achieve a consistent standard
across all companies ALL businesses will be required to adhere to the revised
HCS.
Remember, the updated HCS Rule which was then published earlier this year,
has clear stipulations of GHS additions which state the following:
“Labels are intended to provide an immediate visual reminder of chemical
hazards. Whereas labels in the past could be presented in a variety of
formats using inconsistent terminology and visual elements, labels prepared
in accordance with the requirements in this final rule will be
consistent. Standardized signal words and hazard statements attract
attention and communicate the degree of hazard. Pictograms reinforce the
message presented in text and enhance communication for low-literacy
populations. Precautionary statements provide useful instruction for
protecting against chemical-source injuries and illness”
This would seem a pretty clear statement regarding the format of ALL
Hazardous Material Labeling in the workplace. The rule states -- see (f)(1)(i)
thru (f)(1)(v) -- that every container, save these "immediate use"
containers must be labeled with the following: Product Identifier, Signal Word,
Hazard Statements, Pictograms and Precautionary Statements. This
information will be found on your SDS and should be supplied by your Chemical
Supplier.
SAFETYCAL® is hard at work putting together all the labeling products you
will need to meet the rule head-on with confidence. For now, send us an
email to be put on our announcement list when these products are ready to
launch you into compliance. Visit us at www.safetycal.com
This information is offered for evaluation
and discussion only. For more information contact your local OSHA
representative or go to http://www.osha.gov/dsg/hazcom/index.html
