OSHA Labeling Guidelines-In Brief
The Occupational Safety and Health Administration (OSHA) issued a final rule on March 20 outlining its new Hazard Communication Standard (HCS). This now puts the U.S. in line with the United Nations' Globally Harmonized System (GHS), with the goal of providing uniformity among manufacturers on how a substance is labeled, i.e. as a skin irritant, carcinogen, narcotic, poison, or another deleterious effect.
Safety data sheets may be provided in the new or old format by chemical manufacturers until June 1, 2016, when only the new format can be used. Medical practices, including laboratories, also have until this date to update posted information in the workplace related to hazardous chemicals.
All medical practices, laboratories or businesses affected by this change will need to provide employee training on the new labeling. OSHA training must be conducted by December 1, 2013. Training may be done by local staff utilizing OSHA materials, or a special consultant with expertise in this area. Some state agencies may also provide this service.
Currently, "…[T]here is no standard for how often to give the instruction or how long it should be, but experts say it should be often enough that if an employee is asked a safety-related question, particularly by an OSHA inspector, he or she should know the answer. A system also needs to be in place to ensure that some employees aren’t missed if they call in sick or are on vacation when training is conducted. ..."
So, the bottom-line, is to train, and train frequently such that gaps in training are avoided, document the training, and retain the documentation of training.
Failure to Comply
Lack of compliance with these requirements can result in fines upwards of several thousand dollars. OSHA inspections may identify violations when responding to complaints from staff, or focused inspections of the health care industry.
Additional information on the revised OSHA HCS is available online.