Risk Management
Tuesday | 03 September, 2013 | 9:37 am

Power of protection

By Jeffrey C. Terry & Tom Heebner

Keeping in compliance with new OSHA standards

August 2013 - The Occupational Safety and Health Administration has changed its Hazard Communication Standard, and implementation is slated to begin in December 2013. Is your metal service center ready?

It is typical for metals companies to use various industrial fluids in metalworking processes and overall operations of the company. The fluids and other substances that can be harmful to employees include oils, detergents, surfactants, biocides, lubricants, anti-corrosive agents and chemicals.

Exposure to hazardous chemicals is a serious safety issue. OSHA addresses exposure to hazardous chemicals in its Hazard Communication Standard. 

The standard is designed to ensure employers provide critical information to employees. This federal standard covers specific hazards for each chemical or compound as well as the appropriate and relative protective measures.

In March 2012, OSHA announced a modification to its Hazard Communication Standard to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update creates a consistent worldwide standard that will reduce misunderstandings in the workplace and increase hazard recognition and comprehension.

How the changes affect metals companies

OSHA’s revision will improve the quality and consistency of hazard information while making it safer for workers to do their jobs. The implementation of GHS elements does not change the framework or scope of OSHA’s HCS. The goal is to standardize formats, warning designs and key labeling elements, such as signal words, pictograms, hazard statements and precautionary statements. Major changes include: 

1. Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures. 

2. 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 be provided. 

3. Safety data sheet: Will now have a specified 16-section format and replace what currently is known as a material safety data sheet.

4.Information and training: Employers are required to train workers by Dec. 1, 2013 on the new label elements and SDS format. 

What does your metals company need to do to comply with the revised standard?

Personnel responsible for employee safety and compliance should acclimate to the new changes, and they should ensure that employees are informed and trained to comply with OSHA’s revised HCS. Here are recommendations to help you prepare: 

 Create a list of work practices and job descriptions that involve exposure to hazardous chemicals and train those employees on the revised standard. You may want to be judicious and train your entire staff.

 Document your training program. 

 Give employees an opportunity to ask questions. Collect signatures verifying comprehension of the updated information on labeling and hazard identification.

 Save the new safety data sheets that arrive with procurement orders.

 Set the expectation with your suppliers and vendors that your business is expecting the new SDSs with future orders.

 Replace MSDSs with the new SDSs for your recordkeeping. If you maintain a hard-copy notebook, discard old MSDSs and insert new SDSs. If you use an electronic database, delete old MSDSs and save new SDSs.

• Reassess uses and types of personal protective equipment at the business. Implement a PPE program that covers your hazards; the selection, maintenance, and use of PPE; employee training; and ongoing monitoring to measure effectiveness.

Use these tips and guidelines to modify your hazard communication program so that you are in compliance with OSHA’s revised Hazard Communication Standard. MM



Deadlines have been established for the following action items:

Dec. 1, 2013—Businesses must train employees on the new label elements and safety data sheet format.

June 1, 2015—Chemical manufacturers, importers, distributors and employers must comply with all modified provisions of the final rule.

June 1, 2016—Businesses must update alternative workplace labeling and hazard communication program as necessary and provide additional worker training for newly identified physical and health hazards.


OSHA’s new hazard communication page

GHS and “The Purple Book”

Benefits of harmonization


Jeffrey C. Terry is senior vice president with HUB International Insurance Services in its Los Angeles office. HUB International is a top-10 U.S.-ranked insurance brokerage and risk management firm with headquarters in Chicago. Jeff has specialized in risk management consultation and insurance program design for the metals industry for more than 20 years. Jeff can be reached at This e-mail address is being protected from spambots. You need JavaScript enabled to view it . Tom Heebner, AVP, practices in the HUB Risk Services Division and is based in Chicago. Tom has achieved his Associate in Risk Management, his Associate Safety Professional and his Associate Business Continuity Professional. He holds a Bachelor of Science degree in occupational safety from Illinois State University.

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