Aggregates Manager

October 2013

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ROCKLAW tional Agency for Research on Cancer (IARC) and the National Toxicology Program (NTP) classifications on SDSs and the requirement to include the American Conference of Government Industrial Hygienists Threshold Limit Values on the SDSs. The major changes to the OSHA HazCom standards include hazard classification criteria for health and physical hazards, standardization of chemical labels, a specific format for SDSs, and new training requirements for workers. Employers have already been working to adopt the new requirements and meet the first deadline to train employees on the new label and SDS elements by Dec. 1, 2013. Training on label elements must include information on (1) the types of information the employee would expect to see on the new labels, including the product identifier (e.g., chemical name), signal word ("Danger" is used for the more severe hazards, and "Warning" is used for the less severe hazards), pictograms, hazard statements (i.e., the nature/degree of hazard), precautionary statements (i.e., recommended safety measures), and the contact information for the chemical manufacturer, distributor, or importer; (2) how an employee might use the labels in the workplace (e.g., storage, first aid); (3) a general understanding of how the elements work together on a label (e.g., multiple hazards and precautionary statements); (4) the format of the SDS; and (5) how the information on the label is related to the SDS. [See OSHA Fact Sheet available at OSHA3642.pdf.] There has been some initial confusion over some of the new requirements. For example, the standard applies to combustible dust, but there is uncertainty because the rule does not define combustible dust. This is problematic for materials that may not be shipped in a non-airborne state, but may become subsequently airborne upon further processing or use. To provide guidance, OSHA issued an interpretive letter in March that acknowledges that this hazard warning must be included even when the shipped material is not immediately hazardous. OSHA would accept additional language with the hazard statement that clarifies that the hazard may occur with further processing, handling, or by other means. [See Letter from David Michaels, Assistant Secretary of Labor for Occupational Safety and Health (March 25, 2013), available at https:// table=INTERPRETATIONS&p_ id=28607.] OSHA's Office of Chemical Hazards-Metals in the Directorate of Standards and Guidance also presented a webinar in July that addressed the topic. OSHA clarified that materials that present a combustible dust hazard must be appropriately labeled. The SDS must list the classification of the dust, use the word "warning," and state that it "may form combustible dust concentrations in air." However, pictograms and precautionary statements are not required. [See Robert Iafolla, "New Requirements for Safety Data Sheets, Combustible Dust Clarified by OSHA Official," Occupational Safety and Health Reporter, vol. 43, No. 31, Aug. 1, 2013.] Under the OSHA HazCom changes, chemical manufacturers, importers, distributors, and employers must be in compliance with the final rule by June 1, 2015, except that distributors are not prohibited from shipping containers without the new labels until Dec. 1, 2015. Employers must also update alternative workplace labeling and hazard communication programs as necessary and provide employee training for newly identified physical or health hazards by June 1, 2016. During the transition period from the old standard to the revised standard, parties may comply with either or both. Although compliance with the new OSHA HazCom rules will require additional training, new labels, new SDSs, and changes to existing hazard criteria, the long-term impact should mean less confusion and greater compliance with the HazCom standards. AM AGGREGATES MANAGER October 2013 RockLaw_AGRM1013.indd 35 35 9/18/13 3:21 PM

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