Most teachers of science, be they at the K–12 level or college level, have heard and made use of Material Safety Data Sheets, or MSDSs. Since the introduction of the Hazard Communication Standard (HazCom) (29CFR1910.1200) in 1994, the Occupational Safety & Health Administration (OSHA) has worked to prevent or reduce employees’ exposure to hazardous chemicals in the workplace in many ways, including the mandatory use of MSDSs. Fast forward to March 26, 2012: The Federal Register published the final rule for OSHA’s revision of the HazCom standard with an effective date 60 days after its publication (May 25, 2012). The big news is the revised HazCom standard is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This long-awaited change will provide consistency of hazard information with the rest of the world, making it safer for employees (and students).
HazCom’s bedrock is the requirement of employers to provide understandable information about chemical identities and hazards to employees. The HazCom standard requires chemical manufacturers and importers to evaluate the chemical hazards of the materials they produce and prepare labels and Safety Data Sheet (SDS) information for their customers or users. Employers must train workers on how to read these labels and SDSs so they can use the hazardous chemicals with appropriate safety measures.
According to OSHA, the major changes in the revised HazCom include
- Hazard classification—Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures;
- 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 also be provided;
- Safety Data Sheets—Will now have a specified 16-section format; and
- Information and training—Employers are required to train workers by December 1, 2013, on the new labels’ elements and SDS format to facilitate recognition and understanding (from the GHS—HazCom web page).
For example, the standard format for GHS SDS includes the following: 1. identification; 2. hazard(s) identification; 3. composition/information on ingredients; 4. first-aid measures; 5. firefighting measures; 6. accidental release measures; 7. handling and storage; 8. exposure control/personal protection; 9. physical and chemical properties; 10. stability and reactivity; 11. toxicological information; 12. ecological information; 13. disposal considerations; 14. transport information; 15. regulatory information; and 16. other information. Note that OSHA will probably not enforce sections 12–15, which require information outside the agency’s jurisdiction. The good news is the frustration of different producers supplying differing information on MSDSs will be eliminated with the standard SDS format and the adoption of the GHS’s hazard classification criteria. MSDSs are out, and SDSs are in!
Labeling is another important example of improvement, standardization-wise. The new standard format for labels based on the GHS will be product name; signal word (DANGER or WARNING); hazard statement (nature and degree of risk); pictogram/symbols; precautionary statement (how the product should be handled to minimize risks); name and address of company; and telephone numbers.
Impact on Teachers
The HazCom revision affects teachers in several ways. First, teachers providing science instruction in an academic classroom (e.g., elementary teachers) as opposed to an academic laboratory (e.g., middle school, high school, and college science teachers) are covered under the HazCom standard. Chemicals used at the elementary level, such as alcohol, vinegar, and hydrogen peroxide, are considered hazardous chemicals. In this case, elementary teachers will be required to have training provided by their employers regarding the revised HazCom standard, including hazard classification, labeling, SDSs, and other information to help make the working/learning environment safer for both teachers and students.
Teachers working in academic laboratories in middle schools, high schools, and colleges are exposed to relatively higher levels of chemical hazards and tend to have more prescribed safety compliance protection in the form of OSHA’s Laboratory Standard (29CFR1910.1450). This includes a chemical hygiene plan (CHP) and chemical hygiene officer. The CHP and its standard operating procedures would in fact reflect the revised components of the HazCom standard, including hazard classifications, labeling procedure requirements, use of SDSs, training, and more.
As employers, boards of education are required by OSHA to provide appropriate training in the revised HazCom standard for both academic classroom and laboratory teachers. In addition, employers need to update written HazCom Plans and CHPs to reflect these changes. Science teachers need to advocate to ensure these requirements are met for a safer working/learning environment.
Ken Roy is the director of environmental health and safety for Glastonbury Public Schools in Glastonbury, Connecticut, and NSTA’s science safety compliance consultant. If you have questions about a safety-related issue, send an e-mail to Royk@glastonburyus.org.
OSHA GHS website: The Globally Harmonized System for Hazard Communication; http://1.usa.gov/S2iM8o.
Modification of the Hazard Communication Standard (HCS) to conform with the United Nations’ (UN) Globally Harmonized System of Classific ation and Labeling of Chemicals (GHS): Questions and Answers; http://1.usa.gov/ScjE.