Everything You Need for HCS Compliance
ACA’s HMIS® Implementation Manual provides a comprehensive explanation of HMIS®, and contains the information necessary to align with the written hazard communication program and labeling requirements of the revised OSHA HCS (March 26, 2012):
- A plain-language introduction to the revised HCS;
- Information on evaluating the company-written hazard communication program and using the employee training guide;
- Information on how to read, produce, and use safety data sheets (SDSs) in conjunction with HMIS®;
- A checklist of items OSHA requires in a written hazard communication program;
- Comparison Tables of HMIS® that convert OSHA HCS Classifications to HMIS® ratings;
- Answers to frequently asked questions; and
- A glossary of terms.
How HMIS® Can Help You
Every employer is responsible for providing its employees with a safe and healthy workplace. Hazard communication is an important part of this responsibility. Employers must be trained to recognize the potential hazards of diverse chemicals and properly address these hazards through work practice procedures and the use of PPE. Additionally, hazard communication is required by federal law. The OSHA standard titled “Hazard Communication” found in Title 29 (Labor) of the Code of Federal Regulations (CFR) part 1910, section 1200, requires chemical manufacturers, importers, distributors, and employers to provide hazard information to employees and customers. This standard was revised and published on March 26, 2012 to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and provides specific requirements for labeling, SDS elements, and training.
HMIS® serves as a primary means of complying with the OSHA HCS workplace labeling component and ACA’s HMIS®Implementation Manualmay be used as the basis of a written hazard communication program. The training portions of the implementation process have been realigned to satisfy OSHA’s requirements for workplace labeling of hazardous materials and employee instruction per the revised HCS. The revised HCS outlines specific labeling requirements for manufacturers, importers and distributors of hazardous chemicals; and general requirements for workplace labeling remain the same. As such, ACA’s HMIS® rating system may still be used for workplace labeling as long as it is consistent with the requirements of the HCS. In fact, a tool embedded in the manual allows users to use GHS Classifications to immediately translate to an approximate HMIS® rating.
In the Preamble to the 1983 HCS, OSHA stated that “Labels prepared in accordance with ACA’s Hazardous Materials Identification System would generally be in compliance with this standard.” OSHA recently re-confirmed the acceptability of ACA’s HMIS® program as an in-plant hazard communication tool by stating in the Preamble to the 1994 Revised Final Hazard Communication Standard, that this type of system continues to be an acceptable means of complying with the standard, providing adequate attention is given to target organ hazards during employee training. In the 2013 OSHA Brief titled “Hazard Communication Standard: Labels and Pictograms”, OSHA re-affirmed employers may continue to use their workplace labeling systems as long as it meets the requirements of the OSHA HCS, 1994.
Using the Comparison Tables for GHS/DOT/HMIS® Classifications, Ratings and Pictograms
The revised OSHA HCS mandates new requirements for assignment of hazard ratings based on the United Nations’ Globally Harmonized System of Classification and Labeling (GHS). These new hazard classification requirements affect the hazard information on both safety data sheets (SDSs) and labels. Specifically, to align with the GHS, chemical manufacturers and importers must now evaluate hazards based on specific criteria outlined in the revised HCS and provide GHS-conforming SDS and labels that include a harmonized signal word, pictogram and hazard statement for each hazard class and category. Precautionary statements must also be provided. HMIS® provides a consistent method of hazard communication during this transition period, and will continue to provide a consistent method of hazard communication when the regulation is fully implemented.
ACA’s HMIS® Implementation Manual contains an entire chapter dedicated to applying the Comparison Tables to generate HMIS® ratings using SDSs that contain GHS classifications, pictograms, signal words and hazard statements, offering numerous, step-by-step examples, enabling employers to determine HMIS® hazard ratings from the information provided on shipped container labels and in SDSs. The manual’s exclusive Comparison Tables are designed to provide the user a simple means of converting GHS classifications to HMIS® ratings. The user must first determine the GHS classification of the substance and then go to the Tables to find the HMIS® Health (H), Flammability (F), and Physical Hazard (PH). Keep in mind that the HMIS® philosophy is that the final mixture can reflect HMIS® rating based upon the GHS classification of the mixture or default to the highest HMIS® rating for each of the groups of H, F, and PH.
The manual also includes an appendix that should be used for determining hazard ratings for existing MSDS and non-GHS information.