Last week, OSHA Administrator Dr. David Michaels announced during an address to the American Industrial Hygiene Conference and Expo that the regulatory body will issue the globally harmonized system for classification and labeling of chemicals (GHS) in August 2011. For those of you wondering just what the GHS is, you are not alone. Many individuals in the HVACR trade who don't deal with international shipments, etc., may ask why there needs to be any change to the current material safety data sheets that everyone has gotten so familiar with.
Unfortunately, the current OSHA hazard communication standard used in the United States is not consistent internationally. This can be incredibly burdensome for folks involved in international trade. The goal is to have a set of standards that are universally recognized and easy to use. Numerous countries, including the European Union, have already adopted the GHS, with varying implementation schedules. Here in the U.S., OSHA has been exploring this possibility since 2006, and has had various periods of comments, discussion and other meetings to determine the proper course of action. For more on OSHA's take as to why this should be implemented, click here.
This will impact those in the HVACR trade in a variety of ways. Under the new rule, employers will need to learn the new chemical classification criteria, replace chemical labels, use new Safety Data Sheets (SDS) instead of existing MSDSs, and train all employees in the new hazard communication system as it relates to the various chemicals, refrigerants and other products used in the industry. HCS also requires chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import. The rule also requires they prepare labels and MSDSs in an MSDS management system to convey any hazards and associated protective measures to downstream customers, a.k.a., users of the chemicals - in the case of our trade, HVACR service technicians, contractors, and facilities and maintenance managers.
In addition, all employers with hazardous chemicals in their workplaces must have a hazard communication program, including:
Labels on containers;
Information and training on changes between MSDSs and SDSs; and
Training for employees.
This means that HVACR service contractors storing refrigerants and other chemicals will have to relabel their canisters and other related containers, etc. They also will be required to educate all employees about those materials, what they contain, etc., or possibly subject to rulings for OSHA violations. Make sure to stay on top of these developments, and contact your local OSHA office to make sure your facility is in compliance.
