Chemical Safety

Chemical Safety: A 10-Step Compliance Game Plan

Date First Published on SafetySmart Compliance: November 18th, 2013
Topics: GHS Transition | HazCom |

The keys to avoiding chemical injuries and OSHA citations


azardous chemicals are a leading cause of workplace injuries and illnesses. In addition to costly workers’ compensation claims and embarrassing publicity, failure to control chemical hazards at your workplace is a good way to get into deep trouble with OSHA. Here’s a game plan for avoiding these consequences.

OSHA Chemical Safety Requirements

The starting point for compliance is recognizing the 4 principal sources of OSHA chemical safety requirements:

  1. The Hazard Communication standard, or Hazcom, establishes general safety requirements to ensure that workers exposed to hazardous chemicals are aware of the dangers and how to protect themselves from them;
  2. The new OSHA GHS rule (Globally Harmonized System) changes some Hazcom requirements of Hazcom, including those covering employers that use hazardous chemicals in their workplace;
  3. Subpart Z standards covering specific hazardous substances including asbestos, carcinogens, vinyl chloride, cadmium, lead, benzene, ethylene dioxide, etc.; and
  4. The OSHA Process Safety Management (PSM) standard requires employers that manufacture or use highly hazardous chemicals to implement special programs to prevent and respond to incidents involving those chemicals.

Note: This game plan is designed to ensure compliance with general Hazcom and GHS requirements. SafetySmart Compliance Insider will provide compliance game plans for PSM and specific substances regulated by Subpart Z in future issues.

10 Steps to Take

Step 1: Create Hazardous Chemical Inventory

As with any other hazard, the starting point in managing chemical dangers is to identify and assess hazards at your own workplace. Specifically, you must create a hazardous chemical inventory. You’ve likely already done this.

The twist: The GHS  rule requires manufacturers, importers and distributors of hazardous chemicals to reclassify their products using new GHS criteria by June 1, 2015. They’ll then have to accordingly by Dec. 1, 2016.

Example: ABC Company uses Chemical X. In the current Hazcom system, Chemical X isn’t classified as hazardous. In 2015, the manufacturer of Chemical X re-classifies the product as hazardous. Result: ABC Company now needs to get an SDS and list Chemical X on its hazardous chemicals inventory.

For the Compliance Details & Useful Resources

Step 2: Implement a Written Hazard Communication Program (HCP)

Hazcom requires employers to develop a written HCP for their workplace setting out how they protect workers from hazardous chemicals, including use of MSDSs, labels and other safety measures required by Hazcom.

Bottom line: You should already have an HCP. But by Dec. 1, 2016, you’ll have to revise it so that it complies with GHS changes that we’ll talk about below.

For the Compliance Details & Useful Resources

Step 3: Ensure All Hazardous Chemicals Have Proper Hazcom or GHS Label

Hazcom says employers must ensure that containers of hazardous chemicals have workplace labels listing key safety information about the product. GHS also requires labels but changes what they look like and what information they must include.

Bottom line: From now until June 1, 2016, you must make sure all products have either a traditional Hazcom or GHS label; after that date, only GHS labels will be allowed.

For the Compliance Details & Useful Resources

Step 4: Make Sure Label Alternatives Meet Label Requirements

As before, you’ll be allowed to use label alternatives like signs, placards and process sheets to provide hazard warning information.

Bottom line: If you use any label alternatives, you need to ensure they provide all the information a GHS label must contain by June 1, 2016.

For the Compliance Details

Step 5: Ensure All Hazardous Chemicals Have Proper MSDS or SDS

The MSDS (Material Safety Data Sheet) listing important safety information about hazardous chemicals is a mainstay of Hazcom. GHS is keeping the MSDS institution but changing the form to an SDS, Safety Data Sheet.

Bottom line: From now until June 1, 2016, you must make sure all products have either a traditional MSDS or SDS after that date, only SDSs will be acceptable.

For the Compliance Details & Useful Resources

Step 6: Ensure All Exposed Workers Have Access to MSDS/SDS Binders

Hazcom requires you to maintain a binder containing an MSDS/SDS for each hazardous chemical used, handled or stored at your workplace and ensure that all exposed workers have access to the binder at all times.

Bottom line: There are 2 phases of compliance as follows:

  • Now to June 1, 2016: MSDS binders and electronic access systems must contain either an MSDS or SDS for each hazardous chemical in the workplace;
  • After June 1, 2016: All MSDSs in binders and electronic access systems must be replaced with SDSs.

For the Compliance Details & Useful Resources

Step 7: Provide Chemical Safety Training & Information  

Under Hazcom, you must provide workers “effective information and training” on hazardous chemicals in their work areas.

Bottom line: By Dec. 1, 2013, you must ensure that any of your workers who currently needs Hazcom training, receives training and information about the new GHS requirements.

For the Compliance Details & Useful Resources

Step 8: Provide New and Re-Training As Required

Chemical safety training and information for workers under Hazcom/GHS is not a one-and-done proposition. Any worker not currently exposed to hazardous chemicals who’s assigned to new jobs that involve exposure to hazardous substances must receive Hazcom training and GHS training before starting the job. Exposed workers must receive new or re-training whenever new chemical hazards for which they haven’t already been trained are introduced to their work areas; and all workers must receive Hazcom/GHS training upon assignment to non-routine tasks involving exposure.

For the Compliance Details & Useful Resources

Step 9: Make Changes to Chemical Warning Signs

There are roughly 2 dozen Subpart Z OSHA standards that require employers to post warning signs for a specific type of hazardous substance.

Bottom line: By June 1, 2016, you must change the language of these warning signs to comply with GHS requirements, including signs posted at entry ways to:

  • Asbestos regulated areas
  • 4-Nitrobiphenyl-regulated areas
  • alpha- and beta-Naphthylamine regulated areas
  • Methyl chloromethyl ether areas
  • 3,3’-Dichlorobenzidine areas
  • bis-Chloromethyl ether areas
  • Benzidine areas
  • 4-Aminodiphenyl areas
  • Ethyleneimine areas
  • beta-Propiolactone areas
  • 2-Acetylaminofluorene areas
  • 4-Dimethylaminozobenzene areas
  • N-Nitrosodimethylamin areas
  • Vinyl chloride regulated areas
  • Vinyl chloride hazardous operations
  • Inorganic arsenic areas
  • Lead areas
  • Cadmium areas
  • Benzene areas
  • Coke oven emissions areas
  • Cotton dust areas
  • 1-2-Dibromo-3-chloropropane areas
  • Acrylonitrile areas
  • Ethylene oxide areas
  • Formaldehyde regulated areas
  • Storage areas for clothing and equipment contaminated with formaldehyde
  • Methylenedianiline areas.

For the Compliance Details & Useful Resources

Step 10: Make Sure There’s a System to Monitor Compliance with Label Requirements

Last but not least, you need a system to keep track of and ensure compliance with Hazcom and GHS requirements discussed above.

Related: Chemical Safety Compliance Checklist