HazCom: 2017 Year in Review

Posted on December 15, 2017 | in Safety

As 2017 draws to a close, it’s a perfect time to recap OSHA and Health Canada’s regulatory activities regarding GHS, HazCom 2012 and WHMIS 2015 that have occurred this year. Let’s take a look back at what has happened, and paint a picture for the future of hazard communication.

  • OSHA Stakeholder Meetings on HazCom/ GHS – OSHA held public stakeholder meetings on June 20, 2017 and on November 14, 2017. At these meetings, OSHA:
    • discussed working papers on a labeling of sets and kits, combustible dust, and a global list of hazardous chemicals classified in according with GHS.
    • reaffirmed its intention to revise the Hazard Communication Standard (HCS) to align with Revision 7 of the GHS.
    • gathered input to be considered in preparation for the United Nations Sub Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (UNSCEGHS) meeting to be held in Geneva, Switzerland on December 6-8, 2017.
  • OSHA and Health Canada Regulatory Cooperation Council (RCC) Activities 
    • In the RCC’s June 28, 2017 meeting topics discussed include:
      • Potential changes to the Health Canada’s WHMIS 2015 Hazardous Products Regulations (HPR) and OSHA’s HCS / HazCom 2012, to maintain alignment with GHS and address implementation issues.
      • Development of joint guidance document on labeling requirements for products under WHMIS 2015 and HCS 2012 ,:
      • Development of a joint guidance document on labeling requirements for Hazards Not Otherwise Classified (HNOC), Physical Hazards Not Otherwise Classified (PHNOC) and Health Hazards Not Otherwise Classified (HHNOC).
      • Consideration of subcategorizing Category 1 of Flammable Gases into 1A and 1B, including Category 3 for non-flammable aerosols, and adding a new hazard class for Desensitized Explosives to maintain alignment with the GHS.
      • Proposal by Health Canada to introduce prescribed concentration ranges in the new HPR, which suppliers could use to protect trade secret/ CBI on SDSs, in response to industry concerns. https://www.msdsonline.com/2017/06/30/osha-and-health-canada-discuss-future-ghs-updates-to-hazcom-and-whmis-what-you-should-know/ , that was later published as an official proposed amendment in the Canada Gazette Part  I on October 21, 2017 ( http://gazette.gc.ca/rp-pr/p1/2017/2017-10-21/html/reg2-eng.php).
    • RCC Stakeholder Feedback requested by Government of Canada
      • Published a notice in the Canada Gazette requesting public views on progress to date in its regulatory cooperation work with the United States, and how best to address regulatory divergences between the United States and Canada. The public comment period closes January 8, 2018.
  • EPA Updates 2017 Tier II Reporting Forms to Align with HazCom/GHS Hazard Classifications– Reports due on March 1, 2018, use OSHA’s GHS-aligned HazCom hazard categories in place of the five categories EPA previously required since 1987. This update came about through a final rule issued on June 13, 2016 and will in part make it easier for employers complete their Tier II report, since they can refer to the hazards as they appear on hazardous product SDSs. https://www.msdsonline.com/2016/08/18/epa-revises-epcra-to-conform-with-oshas-ghs-aligned-hcs-what-you-need-to-know/

Let VelocityEHS Help!

For insight into the HazCom successes and failures reported by EHS professionals, download our 2017 Hazard Communication Survey. Be sure to check out our MSDSonline chemical management solutions, especially the award-winning MSDSonline HQ and HQ RegXR Accounts, featuring built-in GHS workplace labeling capabilities, including workplace label integrations with Brady, Avery and Graphic Products DuraLabel printers. Our SDS/Chemical Management Mobile App simplifies complex chemical inventory management tasks and provides on- and off-line employee access to SDSs. Other MSDSonline GHS/HazCom solutions include on-demand training courses, SDS Authoring, Regulatory Consulting Services, and on-demand compliance education via its Enviro and Safety Tool Kits. For additional HazCom guidance, you can also check out our wide variety of resources such as white papers and guides, including our unique OSHA Written HazCom Plan template, which gives you the guidance needed to develop a site-specific and compliant written plan. We look forward to hearing from you to discuss the ways our solutions can help you stay aligned with evolving HazCom requirements.