June 1 marks a critical date for users of OSHA’s 2012 Hazard Communication Standard (OSHA 1910.1200 and OSHA 1926.59). This is the deadline for requiring all alternative labeling for secondary chemical containers to be in place in fabrication and other manufacturing facilities, as well as on job sites. For example, if a chemical (such as paint or thinner) is transferred from a large container to a smaller container, the new labeling must communicate to employees the hazards of the chemical in the smaller container.
In addition, each facility's hazard communication program must be revised to fully comply with the standard, including the Globally Harmonized System (GHS) provisions, and all employees must be trained in the new hazard communication program. Lastly, signage in fabrication shops and on job sites must be enhanced with more descriptive warnings about the hazards present in order to be in compliance with the standard. This will include signage for items such as flammable liquids (1910.106, 1926.52), spray finishing using flammable and combustible materials (1910.107) and welding, cutting and brazing chemicals (1910.252). All of these items must be addressed by the June 1 deadline.
More information on the Hazard Communication Standard can be found in the article "Altering Alerts" from our February 2013 issue, as well as a free recording of AISC’s webinar "Hazard Communication and the Globally Harmonized System (GHS) for Fabricators and Erectors.” In related news, OSHA has also issued their final rule on respirable silica, which significantly lowers permissible exposure limits. Learn more at www.osha.gov/silica.
If you have questions or comments regarding this matter, please contact AISC at safety@aisc.org.