As a follow-up to our Top EHS Trends for 2023 webinar, RegScan is taking a closer look at some of the activities shaping the EHS compliance and sustainability space this coming year. This blog post will focus on a top EHS trend for 2023 revolving around health and safety: upcoming OSHA changes.
OSHA is expected to update the Hazard Communication Standard (HCS) in 2023. This standard is designed to ensure chemical safety in the workplace by requiring workplaces to provide written, and easy to understand, information about the identities and hazards associated with the chemicals stored and used on site. OSHA had already issued a notice of proposed rulemaking to amend this standard (HCS (§ 1910.1200) in 2021 to collect public feedback on this change. More specifically with the HCS update, OSHA is proposing to modify the HCS to maintain conformity with the United Nations Globally Harmonized System of Classification (GHS) which are the nine image placards of classification and labeling which indicate chemical flammability, corrosivity, and other health and environmental hazards. The HCS, first finalized in 1983, provides a standardized approach to workplace hazard communications associated with exposure to hazardous chemicals. The standard was updated in 2012 to align with revision 3 of the GHS to provide a common and coherent approach to classifying chemicals and communicating hazard information. This basically allowed for workers to quickly identify the associated risk of each chemical.
Another update RegScan is following: the Labeling of Chemicals Revision 7 of the GHS, which will align certain provisions with Canada and other U.S. agencies, and address issues that have developed since implementation of the 2012 standard. OSHA expects the proposed updates to the HCS to increase worker protections and reduce the incidence of chemical-related occupational illnesses and injuries by further improving the information on labels and safety data sheets (SDS) for hazardous chemicals. The agency has preliminarily determined that the proposed modifications would enhance the effectiveness of the standard by improving dissemination of hazard information so that employees are more appropriately apprised of the chemical hazards to which they may be exposed.
The key takeaways for businesses regarding these changes are to keep in mind that OSHA’s Hazardous Communications Standard will directly or indirectly affect OSHA’s Top 10 list which serves to alert employers about commonly cited standards so that they are able to take the proper steps to find and fix recognized hazards. The second takeaway to keep in mind relates to worksites that manufacture, store or use hazardous chemicals. Companies can expect increased worker protections expectations. EHS leaders can always fall back on the Hierarchy of Controls to help direct their chemical safety programs.