The HazCom Compliance Deadline Is Only Eight Months Away! Will Your Lab Be Ready?
It seems like time just flies by. In 2012 (which seems like only yesterday), the Occupational Safety and Health Administration (OSHA) adopted the Hazard Communication Standard (HazCom), a regulation that changed the content and distribution of material safety data sheets. However, to allow companies sufficient time to become compliant with the new rules, OSHA pushed out the actual date of adoption until June 1, 2015.
Three years ago I remember thinking that this date was so far in the future, that all laboratories would have plenty of time to become compliant. Well, the due date is now only eight months away and many laboratories haven’t even started preparing for the switch.
If your laboratory falls into this category, don’t lose hope yet. Although it is nearing crunch time, it is still possible to be compliant by the deadline, especially if you consider these suggestions:
Perform a Chemical Inventory – The first step towards HazCom compliance is determining specifically what types of chemicals are currently stored at your facility. This requires performing a detailed audit of all current on-hand chemicals across all locations. Besides noting the name of each chemical, you will also need to note the location where each chemical is stored. This information will be needed to design a training program focused on ensuring that employees working with these chemicals know and understand the risks.
Determine SDS Needs – Once you have identified all of the on-site chemicals, the next step is to determine whether the Safety Data Sheets (SDS) for each chemical has been updated. In general, this information should be provided by the chemical supplier. However, if you have not received an updated SDS sheet from your supplier, it might be time to call them and find out when it will be coming.
Update Labels – Another aspect of the new HazCom compliance is that all on site chemicals will have to be relabeled with updated classification information. In general, this labeling will be the responsibility of the supplier. However, if an experiment in the laboratory results in the creation of a new chemical substance that may be reused, an in-house label will have to be attached. Per the new regulations, this label will have to clearly identify the content and classification of the container.
Develop a Training Program – The new HazCom regulation also requires that employees be trained and informed of the risks associated with the chemicals they use regularly. Although this is not a new rule, it should be noted that training programs will have to be updated to reflect the modified information contained on the new SDS forms. As the deadline draws near, safety officers need to compare the old SDSs forms to the new ones as they arrive and update employee training programs appropriately.
Document Policies – Best practices suggest that laboratories need to document the operational procedures and safety rules for all tasks associated with the handling and management of chemicals. This information is important organizational knowledge that can be used as personnel join or leave the laboratory.
For companies that have hundreds or thousands of chemicals stored on site, the HazCom regulation may appear daunting. However, a simple solution to managing this problem is to implement a chemical inventory management system.
The benefits of a chemical inventory management system include the automatic tracking of on-hand chemicals in terms of quantity, type and location. A well-designed system will also track and store digital copies of the SDS forms, making them easy to locate and distribute. Version controls can be added to compare and highlight differences between SDS versions. This information can then be used to update employees regarding any associated risk.
Although 2012 was only two years ago, it seems like it was only yesterday. If you are not carefully planning, you may find D-Day upon you and your laboratory scrambling to reach compliance. For more information regarding how a chemical inventory management system, like Accelrys CISPro, can help ensure compliance on that date, please visit our website today.