ASSOCIATION INSIGHTS
Are You Ready for New Hazard
Communication Requirements
OSHA requirements are changing and you must be in compliance. By Gary Jones & Caitlin Seiler
n March 2012, OSHA revised its Hazard Communications Standard (HCS)
to align with the United Nations'
Globally Harmonized System of Classification and Labeling of Chemicals
(GHS). Included in the changes impacting
printing operations are a new labeling system and a mandatory standardized format
for Safety Data Sheets (SDS).
The new requirements are being phased
in and will be complete by June 1, 2016.
Companies are urged to take the following
steps to update or develop a compliant
Hazard Communication program:
1. If you are a Printing Industries of
America's member, you can use your member login to access the dedicated Hazard
Communication page at www.printing.
org/hazcom. Here you will find the materials that PIA is providing free of charge to
assist you with compliance, including:
• A guidebook that provides information
about the revised Hazard Communication
Standard and compliance requirements.
• A video and PowerPoint presentation
that can be used by members to train their
employees about the revised Hazard Communication Standard.
• Other supporting materials such as a
transition guide, sample written program,
compliance checklist, training forms, sample letters, etc.
I
2. If you have not already conducted
initial employee training that was due by
December 1, 2013, do so as soon as possible! Initial employee training must cover
the new labeling elements, including product identifiers, signal words, hazard statements, precautionary statements, and pictograms as well as the standardized format
of Safety Data Sheets, which are replacing
Material Safety Data Sheets (MSDS).
Employees required to be trained are
those who are directly exposed to or could
be exposed to a product with a hazardous chemical. This includes employees
involved in prepress, production, maintenance, shipping and receiving, and anyone
else who might be exposed to a chemical.
3. If your facility does not have a written
hazard communication program, a GHScompliant program must be developed. If
you need one, a sample can be found at
www.printing.org/hazcom. Any existing
program should be reviewed to ensure that
it is current, and as a minimum, any references to MSDS need to be replaced with
SDS. The program should also be reviewed
to ensure that the other necessary elements reflect the current practices, such
as the location of the SDSs, responsible
parties, etc.
4. If the inventory of products and
chemicals currently being used has not
been updated, a comprehensive inventory
of all products must be conducted.
5. Compare the inventory of products
and chemicals to ensure that either an
MSDS or SDS is present and up to date.
(Until June 1, 2015, both MSDS and SDS
are acceptable. After that date only SDS
will be allowed.) For any chemical or product that does not have an MSDS or SDS,
one should be obtained. Any MSDS that
is more than several years old should be
replaced with an updated sheet.
6. Determine what in-plant container
labeling system will be used under the
revised standard that will not contradict
the GHS labeling system. If updates are
needed, they must be completed by June
1, 2015, when the vendors must have
made the changes to their shipping containers to meet the new requirements.
Many printing companies use the Hazardous Material Information System (HMIS)
approach. If this system will be continued,
additional information and training will
be required for employees. ◗◗
Gary Jones is vice president of EHS Affairs
and Caitlin Seiler is EHS specialist for Printing
Industries of America. Contact the EHS Affairs
Department at ehs@printing.org or 412-2591794. For more information about PIA, visit
MyPRINTResource.com/10013918.
James Burn Lhermite
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