OSHA's Hazard Communication Standard(HCS 2012 or HazCom 2012) is the adaptation made in the United States of the GHS and included in the Federal Register 17574 (29 CFR Parts 1910, 1915 and 1926), which has been mandatory at any workplace in the United States since June 2015.
Likewise, the Hazard Communication Standard (HCS/HazCom 2012) regulates the content of Safety Data Sheets (SDS), in accordance with Appendix D to 1910.1200, and also the content of labelling in accordance with Appendix C to 1910.1200.
The Hazard Communication Standard (HCS/HazCom 2012) is aligned with the third revised edition of the Globally Harmonized System (GHS). However, it does not implement the entire system, as the HCS excludes hazard categories from the Purple Book and incorporates amendments.
Classification:
Unlike the third revised edition of the Globally Harmonized System (GHS) only has two typesof hazards for the purposes of classification and labelling:
Physical Hazards.- Health Hazards.
And it excludes Environmental Hazards.
The Hazard Communication Standard (HCS/HazCom 2012) excludes the following hazard categories from the UNECE's GHS:
- Physical Hazards:
- ✘ Flammable gases, category 1B.
- ✘ Aerosols, category 3.
- ✘ Chemicals under pressure, all categories.
- ✘ Desensitised explosives, all categories.
- ✘ Pyrophoric gases and chemically unstable gases, all categories.
- Health Hazards:
- ✘ Acute toxicity, category 5.
- ✘ Skin corrosion/irritation, category 3.
- ✘ Aspiration hazard, category 2.
- Environmental Hazards:
- ✘ All hazard classes and categories are excluded.
However, the Hazard Communication Standard (HCS/HazCom 2012) includes the following own hazard classes and categories (not listed in GHS):
- Hazards Not Otherwise Classified (HNOC).
- Combustible dusts.
- Simple asphyxiants.
Besides the Hazard Communication Standard (HCS/HazCom 2012), there are other hazard communication systems such as the NFPA 704 and the HMIS:
- • The NFPA 704:which explains the 'Hazard Diamond', is maintained by the National Fire Protection Association and used to communicate the hazards of materials for emergency response.
- • The HMIS: Hazardous Materials Identification System, is a numerical hazard rating that incorporates the use of labels with colours developed by the American Coatings Association (ACA). The HMIS colour bar is similar to the fire diamond, created by the National Fire Protection Association (NFPA). The colour bar is not solely for emergencies and is used to convey broader health warning information.
Neither system is mandatory, and both can be used on labels and on Safety Data Sheets (SDS) for complementary information, as long as they do not conflict with the indications of the Hazard Communication Standard (HCS/HazCom 2012).
Labelling:
The Hazard Communication Standard (HCS/HazCom 2012) is a regulation applicable to workplaces, with the content of the label reflected in Appendix C to 1910.1200.
Products classified in accordance with Appendices A and B to 1910.1200 must clearly and visibly include the product name, hazard pictogram(s), signal word, hazard statements, precautionary statements and supplementary information, together with supplier information on the substance or mixture.
In addition, not only does the Hazard Communication Standard (HCS/HazCom 2012) require the labelling of chemical products to which workers are exposed in the workplace, but also relevant labelling in different areas of the workplace.
Given that the Hazard Communication Standard (HCS/HazCom 2012) is a regulation intended exclusively for the professional/Manufacturing industry, the following regulations are used for the labelling of chemical products intended for consumer use:
- • Consumer Product Safety Act (CPSA).
- • Federal Hazardous Substance Act (FHSA).
Safety data Sheet (SDS):
The Hazard Communication Standard (HCS/HazCom 2012) requires the chemical manufacturer, distributor or importer to provide safety data sheets for each hazardous chemical to downstream users in order to communicate information about these hazards.
The information contained in the SDS must be in English and, as required by the OSHA, must provide the specific minimum information detailed in Appendix D to 29 CFR 1910.1200.
- Identification.
- Hazard(s) identification.
- Composition/information on ingredients.
- First-aid measures.
- Fire-fighting measures.
- Accidental release measures.
- Handling and storage.
- Exposure controls/personal protection.
- Physical and chemical properties.
- Stability and reactivity.
- Toxicological information.
- Ecological information.
- Disposal considerations.
- Transport information.
- Regulatory information.
- Other information, including date of preparation or last revision.
The Safety Data Sheet (SDS) must also contain sections 12 to 15 in order to be consistent with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), but the OSHA will not enforce the content of these sections because they refer to matters handled by other agencies.
Section 15 of the Safety Data Sheet (SDS) should contain national and/or state-specific regulatory information such as California's Proposition 65, state-specific right-to-know inventories, etc.
Toxic Substances Control Act (TSCA):
The Toxic Substances Control Act (TSCA), administered by the Environmental Protection Agency (EPA), regulates the introduction into the United States of new or existing Chemical substances.
Substances and substances in Chemicals must appear in the TSCA inventory in order to be manufactured or imported into the United States.
In order to manufacture or import chemicals, all substances in chemicals must:
- Appear in the TSCA inventory, or
- be exempt, or
- be regulated by other USA laws.
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