Over the next few years, the look of, and information on, material safety data sheets and product labels will change because the federal Occupational Safety and Health Administration (OSHA) has adopted revisions to the Hazard Communication Standard.
The revisions to the standard include requiring all employers (including dental practices) using hazardous substances to train employees on the new hazard communication system. The federal OSHA's deadline for employers to train employees is Dec. 1. Compliance with other elements of the rule must be met by June 1, 2016.
The major changes to the Hazard Communication Standard include:
- Hazard Classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures. (The term "hazard classification" replaces the term "hazard determination.")
- Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
- Safety Data Sheets: Must be done in a specified 16-section format and order of information. (Note the word "material" was dropped, therefore the abbreviation "SDS" will be used instead of "MSDS.")
OSHA made the changes to conform with the United Nations' Globally Harmonized System (GHS) of Classification and Labeling of Chemicals, which experts believe to be a more effective system for communicating hazards to employers and workers. Cal/OSHA is adopting similar revisions to its regulations because it is required to be at least as effective as its federal counterpart.
In addition, manufacturers of products produced and sold around the world benefit from having to comply with one less set of regulations. Manufacturers must use the new label format by June 1, 2015. The two different hazardous communication systems will coexist until June 1, 2016. By that date, employers must update alternative workplace labeling and hazard communication programs as necessary, as well as provide additional employee training for newly identified physical or health hazards.
Employers are required to have a written Hazard Communication Plan. CDA has updated the sample plan, and developed PowerPoint presentations that can be used for employee training. These are available on cda.org/compass.
Staff training may be conducted by a knowledgeable dentist or staff person using OSHA and CDA materials, or by a consultant who specializes in this area. A thorough understanding of the new system by all staff is the goal of the required training.
Additional information on changes to the Hazard Communication Standard is available on federal OSHA's website, osha.gov.