September 23, 2016

OSHA Rep Updates Product Stewards on GHS and Beyond

Companies should be in compliance with GHS labeling requirements by now. That said, OSHA continues to issue guidance. Maureen Ruskin, office director, office of chemical hazards at OSHA, talked about that guidance and shared updates on the agency’s regulatory agenda.

Ruskin reminded attendees that they should be labeling their containers with updated pictograms and including updated safety data sheets. There is some discretion for companies working through existing stock with old labels. By June 1, 2017, companies should have worked through all existing stock and only be using updated labels.

Highlighted Issues

Ruskin talked about enforcement activity in the past couple years. Companies that triggered violations around hazard communications were mostly related to requirements that haven’t changed – if they didn’t have a written employee training program or updated safety data sheets, for instance.

Another issue is the amount of information required on labels. In some cases, packaging is too small to include all the information. OSHA has looked to examples from the UN and issued letters of interpretation for what’s allowed when there’s not enough room. Ruskin pointed out that that the signal word and the pictograms must go together, but the rest the information can be on a different part of the label, which provides companies with some flexibility.

Hazard Classification Guidance

OSHA published Hazard Classification Guidance to address how companies would make a hazard classification in general terms, how to identify chemicals with CAS numbers, where to look for data and more. The publication also addresses physical and health hazards and provides guidance along with the classification criteria. Each chapter covers a different hazard class, with criteria for the substance and a discussion on the criteria for mixtures.

Guidance for the Weight of Evidence

OSHA also published Guidance for the Weight of Evidence. This document, in its comment period at the time, explains HCS’ weight of evidence analysis requirements. “We have kept it strictly to how you can apply this to the hazard communication standard,” said Ruskin. The document addresses how to use authoritative evaluations.

To summarize, evaluations are given greater weight for studies that are in humans or that can be readily translated to humans. Also they look for animal studies and how they were conducted along with the statistical power of the results. You might also have to do a conflict resolution if some studies are positive and some negative.


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