Hazard Communication Requirements

The Occupational Safety and Health Administration's (OSHA) Hazard Communication (HAZCOM) standard requirements, applicable to concessioners, changed in December 2013. Concessioners must maintain regulatory compliance.

The OSHA HAZCOM standard has been in place for many years, and OSHA's general requirements for employers include concessioners. Concessioners must:

• Develop and implement a written HAZCOM program that meets OSHA requirements.
• Maintain an inventory of chemicals used and stored in the workplace.
• Maintain Material Safety Data Sheets (MSDSs) for chemicals used and stored in the workplace.
• Label chemical containers with the name and hazards of the chemical.
• Train employees on the HAZCOM program.

Globally Harmonized System of Classification and Labeling of Chemicals

In 2012, OSHA revised the HAZCOM, or the "right-to-know" standard, to use an approach called the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This United Nations' vetted revision improves the quality and consistency of hazard information, making it safer for workers to do their jobs. Many of the HAZCOM requirements concessioners are familiar with remain the same. However, a few requirements have changed:

• The GHS requires that chemical containers be labeled with a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category; and
• Safety Data Sheets (SDSs), formerly known as Material Safety Data Sheets, are standardized to include 16 specific sections, making it easier for employees to find important protection information consistently.

This revamped standard is not only an employee's "right-to-know" but also "right-to-understand." To comply with the new GHS requirements, concessioners should take the following steps:

1. Provide training to employees on the new label elements and safety data sheet format.
2. Review and update their HAZCOM programs to incorporate the new GHS labeling and SDS requirements.
3. Work with employees to re-label containers with the newly required elements.
4. Obtain new copies of chemical SDSs in the GHS format.
5. Provide additional employee training for newly identified physical or health hazards.

For more information, OSHA has developed the following resources to clarify the update for employers and employees:

• HAZCOM Standard Final Rule Fact Sheet
• Side-by-Side Comparison of the 1994 HAZCOM Standard and the 2012 HAZCOM Standard
• GHS Pictograms

OSHA has developed a Fact Sheet on training requirements, and has free training materials in English and Spanish on OSHA's website. If you have questions on implementing the GHS in your concession operations, contact us.