Grain News

NGFA: Training Required by Dec. 1 on New Hazard Communication Label Elements and Safety Data Sheet

Date Posted: September 23, 2013

This article is reprinted by permission from the NGFA Newsletter, Volume 65, Number 18, Sept. 20, 2013.

by Jess McCluer, Director of Safety and Regulatory Affairs

Employers in the grain handling, feed, grain processing and other industry sectors face a Dec. 1 deadline to train workers on the new label elements and safety data sheet (SDS) formats required under the Occupational Safety and Health Administration’s (OSHA’s) revised hazard communication standard.

The new label elements and safety data sheet (SDS) formats required under the standard take effect in 2015 and 2016.

But the standard requires training to be conducted by Dec. 1 on the standard’s new labels and pictograms, as well as standardized data sheets.

The standard applies to all U.S. employees who come into contact with hazardous chemicals in the workplace.

The hazard communication standard historically has been one of the most frequent violations cited by OSHA inspectors – often because employers do not have a written hazard communication compliance program or conduct the required training of employees.

In fiscal year 2012, it once again was the most frequently cited OSHA violation standards among the industry.

In March 2012, OSHA revised its hazard communication standard to align it with the U.N. Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

The GHS is an international approach to standardizing hazard communication.

“These changes will help ensure improved quality and consistency in the classification and labeling of all chemicals, and will also enhance worker comprehension,” according to an OSHA statement.

Importantly, the new training requirements do not change the basic requirements for employers, such as the obligation to:

1) ensure that labels on incoming containers of hazardous chemicals are not removed or defaced; maintain safety data sheets; and

2) ensure that safety data sheets are readily accessible to employees during each work shift.

The revised standard also still requires that employers develop, implement and maintain a written hazard communication program.

The National Grain and Feed Association (NGFA), through the leadership of its Safety, Health and Environmental Quality Committee, is developing educational and training materials for the industry on the hazard communication standard’s new labels and pictograms, as well as standardized data sheets on which training is required by Dec. 1.

In addition, the NGFA will be conducting an informational webinar in the upcoming weeks, and will conduct an in-person training session for elevator managers and employees on Dec. 8 during its 42nd annual Country Elevator Conference, Dec. 8-10 in St. Louis, Mo.

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