HazCom 2012

This site is intended to provide links to resources and information regarding the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HCS), or the “Right-to-Know” law. The underlying objective of HCS is that information about the identities and hazards of chemicals used in the workplace be made available and understandable to workers.

In 2012, OSHA revised the HCS to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Specific changes to the HCS include:

  1. New label requirements for chemical (non-pesticide) labels.
  2. A change from Material Safety Data Sheet (MSDS) to Safety Data Sheet (SDS).
  3. A new, 16-section standard format for the Safety Data Sheet (SDS).

To be incompliance with the HazCom 2012 standard, employers must provide training to all their employees who deal with hazardous chemicals by Dec. 1, 2013. The training must be given in the language understood by the worker and focused on the label elements of non-pesticide chemicals and the new SDS format applicable to both pesticides and non-pesticides

Here are some resources to help you and your staff be in compliance with OSHA’s new standard:

More information on the HCS can be found on OSHA’s hazard communication safety and health topics page at https://www.osha.gov/dsg/hazcom/index.html

Pesticides and Safety Data Sheets

Generally, every pesticide sold or distributed in the U.S. must be registered by EPA. In granting a registration, EPA must determine that the pesticide’s “labeling” complies with the requirements of FIFRA. FIFRA defines “labeling” to include all written, printed, or graphic matter accompanying the pesticide at any time. One of FIFRA’s requirements for labeling is that it not be false or misleading in any particular.

EPA regards SDSs for pesticides to be “labeling” when they accompany the pesticide. SDSs that comply with the HazCom 2012 could be viewed as inconsistent with the FIFRA labeling because some of the label elements (e.g. pictograms, signal words, and or hazard statements) could differ for the same hazards. For example, the GHS uses only two signal words, “danger” and “warning,” while current pesticide labels may also bear the word “caution” for less toxic products.

To provide an adequate explanation so the labeling is not misleading, EPA recommends registrants include in their SDSs the FIFRA label information and a brief explanation for any differences between that information and the SDS information. Section 15 of the SDS (“Regulatory Information”) is an appropriate place to insert the information. At a minimum, the registrant should reprint the FIFRA hazard statements (e.g., “fatal if swallowed”), signal word, and symbol (if required) in this section.

Read the PR Notice regarding EPA’s Statement on SDS as Labeling.

Additional Resources

  1. Pesticide Labels and Safety Data Sheets. PowerPoint presentation with notes created by Carol Black, Washington State University and modified by Betsy Buffington, Iowa State University.
  2. Globally Harmonized System Change from Material Safety Data Sheet to Safety Data Sheet (English). Globally Harmonized System Change from Material Safety Data Sheet to Safety Data Sheet (Spanish). PowerPoint presentations by the Penn State Pesticide Education Program.
  3. The Penn State Pesticide Education Program YouTube channel has a video entitled HazCom 2012 Training for Mushroom Industry in English and another in Spanish.