The landscapes of hazmat regulations, chemical classifications and employee HAZWOPER training are constantly changing. And American industry leaders can expect more changes soon! In February 2021, the US Occupational Safety and Health Administration (OSHA) finally published a notice of proposed rulemaking (NPRM) for the HazCom standard. OSHA's goal aligns with the most recent revision of the UN's GHS.
Today we'll take a high-level view of two considerable changes on the horizon for chemicals manufacturing / storage. As always, know the team at Wise Businessware is working to stay ahead of the curve. If your crew needs updated online compliance safety training resources once the rules are finalized, contact us.
OSHA's latest NPRM proposes several significant changes to chemical classification of aerosols and explosives.
OSHA plans to follow UN guidance and expand the current Flammable Aerosols hazard class to include non-flammable aerosols.
Know that HazCom 2012 was based mostly on data provided by the transportation sector. So historically, most aerosols were classified as gases under pressure. But OSHA now believes this classification does not communicate the real hazards of aerosols because aerosol containers vary greatly and have different failure mechanisms from one to the next.
Ultimately, the proposed change will have a profound impact on the authoring of SDSs (formerly known as MSDSs) by aerosol manufacturers, transporters, wholesale warehousing, retail placement and may affect end-user storage as well.
Next, we consider OSHA's suggested updates regarding a new class of physical hazards: desensitized explosives.
OSHA plans to add a new physical hazard class for desensitized explosives. The proposal states there will be four new categories (1,2,3 and 4) within the new hazard class.
For now, know that:
Currently, these chemicals are classified as explosives. They're stored with precautionary warnings to address the measures needed to keep a chemical stabilized, such as "keep wetted." Now, OSHA agrees with the UN, and says a separate hazard class is necessary to ensure the specific hazards associated with work and storage are plainly communicated to your crew.
OSHA published a table in the NPRM that describes the major industries affected by the proposed changes. (See page 49 of NPRM.)
They are:
Like ripples on water after a pebble is tossed into a pond, it's easy to imagine change rippling outward for warehouse personnel, hazmat CDL drivers, and various other points on the "cradle to grave" scheme of hazardous waste that will undoubtedly be affected, too.
So far, we've addressed two significant changes to hazardous materials labeling that are on the horizon. But the NPRM covers more issues like:
And a proposed change to SDSs that will allow manufacturers to retain their trade secrets by keeping chemical percentages listed on SDSs confidential — in other words, manufacturers won't need to publish the exact recipe of hazardous chemicals on the label under the proposed rules.
This is what it all comes down to. EHS software helps you stay proactive, identifying and correcting risks before they cause an accident.
Take a closer look at our EHS software solutions.
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