Room for Improvement in HazCom 2012 Safety Data Sheets

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OSHA adopted UN GHS recommendations and implemented one of its many revisions for the HazCom 2012 standards. However, no system is perfect as can be seen by the fact that UN GHS itself has been revised so many times. OSHA too has recognized that while its adoption of GHS has been a tremendous leap in providing greater safety for employees at workplaces, there may be room for improvement. To this end it has decided to obtain feedback on its Guidance on Data Evaluation For Weight of Evidence Determination Application to the 2012 Hazard Communication Standard. The aim, ultimately, is to help in preparation of accurate SDS and labels that contribute to greater safety and health of workers.

Why this need? The HazCom 2012 makes it incumbent on manufacturers/importers to specify precise nature of health and physical hazards of chemicals based on consulting of full range of scientific evidence as available. This is interpretative and puts manufacturers in a quandary. How much should they search from available scientific literature to arrive at a point that is satisfactory? This may be taken to mean that it is better to err on the side of maximizing risks of any chemical. This exercise of scanning scientific literature is beyond most manufacturers who lack resources but it is a task handled with ease by experts at who specialize in preparation of HazCom 2012 Safety Data Sheets with absolute precision and without any ambiguity.

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OSHA’s new document, still in a draft stage, helps authoring professionals get clarity in the case of conflicting data. Still, since this is in the evolutionary stage, professional authoring companies must use their own knowledge and expertise in arriving at the right conclusion that remains valid today and stands the test of any information that may be uncovered in the near future. OSHA may take its time to perfect the guidelines based on feedbacks from users but ICSDS professionals use their knowledge and experience to create SDS and labels that are as precise as is possible. Employers retaining ICSDS are reasonably assured that their workplaces are as safe as can be for their employees through the development of meticulously crafted SDS and training programs.

Change eventually may come about. In the meantime, ICSDS works in close coordination with employers and their managers to ensure implementation of an effective communication system that keeps employees fully updated about safety information of chemicals.

It is important to build a safety culture at work, an area on which ICSDS focuses and that safety culture is one that is open to changes that may come about in time. For the present and for the near future, ICSDS involvement helps managers keep current and inform their employees accordingly. Safety can always be improved and the HazCom2012 safety data sheet is the starting point. Preparation, followed by support and ongoing updates is the surest way to improve safety, regardless of when and how OSHA brings about improvements.


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