Pallet companies that have not already begun training employees to understand the Occupational Safety and Health Administration’s (OSHA) new hazard communication (HazCom) standard should begin soon.
HazCom is intended to ensure that anyone working around hazardous chemicals stay informed of potential risks and knows what to do if exposed. Last year, OSHA finalized new HazCom rules that incorporate the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), a harmonized system used in Mexico, Europe, Asia, Australia and other countries. Under the new rule hazard warnings, material safety data sheets (MSDS) and labels, will have a standardized format. According to OSHA, the information required on the MSDS will remain essentially the same as that in the current standard. The main change will be the format requirements. Previously, there were no specific rules about what a chemical label or MSDS must look like. All employers are required to train any workers that could potentially be exposed to any hazardous chemicals on the new labels and MSDS requirements by Dec. 1, 2013.
Though at first glance it may not seem like regulations regarding hazardous chemicals apply to pallet companies, most pallet companies deal with substances that are classified as hazardous in one way or another. Some hazardous chemicals that a pallet company might have on-site include gases, hydraulic fluids, equipment lubricants, greases and mold treatments. Therefore, many pallet plants are required to provide the required HazCom training to their employees.
Combustible dust is also an issue that wooden pallet companies need to pay attention to under HazCom since wood dust is considered combustible and some pallet companies have already received inspections as part of OSHA’s combustible dust national emphasis program. Because of the way wood dust is addressed in the new standard, it is likely to cause significant confusion for industry members. In the revised standard, OSHA has added it to the definition of hazardous chemicals, which means that combustible dust hazards must now be addressed on labels and MSDS. However, OSHA did not provide a definition for combustible dust due to ongoing rulemaking for it. Instead, the standard provides guidance on how to define combustible dust for the purposes of complying with HazCom by pointing to existing documents, such as OSHA’s Combustible Dust National Emphasis Program Directive (CPL 03-00-008) which includes an operative definition and provides information about current responsibilities in this area. It also recommends looking at voluntary industry consensus standards, particularly those of the National Fire Protection Association (NFPA), that address combustible dust. Pallet companies should keep up-to-date on what is happening regarding combustible dust as OSHA will likely be issuing more guidance as news rules are finalized.
Any workers that could potentially be exposed to these or any other hazardous chemical must receive training on the new standards before the Dec. 1 deadline. In order to be in compliance with the training requirements, employers must fulfill certain obligations. Merely giving workers the MSDS to read is not enough. OSHA requires that the training be conducted as a forum that includes an explanation of both the hazards of the chemicals in the work area and how to use the information available as part of the company’s HazCom program. It can be in the form of classroom instruction, audiovisuals or an interactive video, but it should include a chance for employees to ask questions to make sure that they understand the information they are being given. As with all OSHA training requirements, the training must be given in a way that the workers can comprehend it. This means that if an employee receives job instructions in a language other than English, then the training and related information must also be conveyed in that language. Though employers are required to compile a list of all hazardous chemicals in their facilities, training does not need to be conducted on each specific chemical found. It can instead be conducted by categories of hazard (such as carcinogens, sensitizers or corrosive) that employees could encounter while working.
Employers should keep records of the training that takes place and which employees received it. OSHA may request this information at some point, and it is the only way to show you complied with training requirements. Training must take place as soon as a worker is
assigned to work with a hazardous chemical.
There are many resources available to help conduct the required employee training both from OSHA as well as private companies. On its HazCom page (www.osha.gov/dsg/hazcom), OSHA has a number of resources available in both English and Spanish that can be used to assist with training. These include fact sheets, briefs and quickcards that discuss the training topics that employers must cover for the initial Dec. 1, 2013 deadline. OSHA’s website also has explanations of the new labeling elements and a step-by-step guide for employers to create a label that meets the requirements of the revised standard.
For companies that do not wish to conduct the required training themselves, private companies offer a range of options in different formats, such as the online training available from MSDSonline (http://www.msdsonline.com) or DVD and CD-roms available from J.J. Keller & Associates (http://www.jjkeller.com) as well as many others. Whatever method of training that you choose, make sure that it includes all of the elements required by OSHA, as the employer is the one ultimately held responsible for meeting the requirements.
The training requirement is only the first part of the revised HazCom standard to go into effect. The rest of the standard will be phased in over the next several years. However, chemical manufacturers and importers can begin using new formats for labels and MSDS at any time during the transition period, emphasizing the need for training to be completed earlier rather than later. Other dates for employers to be aware of are:
• June 1, 2015: OSHA will begin enforcing all the new provisions of the rule, and
• June 1, 2016: By this time, employers must have updated labels as well as a written HazCom program.
A complete timeline with more details and information on the training requirements are available on OSHA’s HazCom webpage.
