In February 2016, the Occupational Safety and Health Administration (OSHA) issued two guidance documents to help manufacturers, importers, and employers implement the 2012 Hazard Communication Standard (HCS) and improve the quality and consistency of information provided on safety data sheets (SDSs) and labels as well as in trainings. Specifically, the guidance clarified procedures for classifying chemical hazards in accordance with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), Revision 3, including data collection methodologies, detailed technical considerations for conducting weight-of-evidence evaluations for each hazard endpoint, and strategies for documenting approach and conclusions. Importantly, the guidance clarified that it is the responsibility of “chemical manufacturers” to conduct hazard assessments and prepare accurate SDSs and labels to protect workers’ safety and health.
The requirement for all manufactures and importers to conduct detailed hazard evaluations presents significant technical and logistical challenges, for both large companies with extensive chemical portfolios as well as smaller companies that might have more limited toxicology capabilities. These challenges mainly arise from the need to resolve data discrepancies and reconcile the results of assessments conducted by various authoritative agencies, which may reach different conclusions for the same chemical. As emphasized in the guidance, in order to meet these challenges, it is important for manufactures to rely on qualified individuals to conduct well-researched and well-supported weight-of-evidence evaluations and methodically document their hazard classification logic and reliance materials.
Gradient has over 30 years of experience evaluating human health, aquatic toxicity, exposure, and risks associated with chemicals in a wide variety of settings. We have conducted thousands of hazard assessments for the purposes of developing SDSs using the principles outlined in the OSHA documents. We believe that the depth of our chemistry, toxicology, and ecotoxicology experience, in combination with existing hazard assessment procedures and tools, is unique and enables us to develop scientifically sound, cost-effective compliance strategies for our clients.
Occupational Safety and Health Administration (OSHA) 2016. “Hazard Communication: Hazard Classification Guidance for Manufacturers, Importers, and Employers.” OSHA 3844-02 2016. 424p. Accessed on February 17, 2016.
Occupational Safety and Health Administration (OSHA) / Guidance on Data Evaluation for Weight of Evidence Determination: Application to the 2012 Hazard Communication Standard (Draft). 2016.