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While the look and name of MSDS will change, the same information will be there. Perhaps, even a chance to raise the bar on our training and understanding of specific hazards. Another feature of the SDSs will be mixture information. In the coatings industry, we have had a MSDS for each part of two-part component systems for a long while. However, we did not have a MSDS for the mixed product. Now that information will be found as well. The manufacturer must provide any data it has on the mixed material by either direct testing or by "bridg- ing." Bridging is calculating the effects of a substance based on the properties of each component. The requirement that the SDS be printed in English has remained the same. OSHA has pushed for all safety- related material to be presented in whatever manner or language is needed for worker protection. The GHS is less concerned with any specif ic language and more concerned that employees are protected from the hazards of their work. Nonetheless, the new revision does require the availability of SDS in the English language. OSHA has also required the contin- uation of label integrity. Whatever labeling the manufacturer has placed on its product, the end user's employer must ensure the labeling remains intact and is replaced if necessary. Training The big question that has employers abuzz: Is training required and by when? The answers are dependent on who the employer is. First, what the training must include. The minimum t raining must include a disclosure of what methods and observations will be used to detect exposures in the workplace. The hazard classi f icat ion of the chemi- cal along with the physical, health, and other hazards must be noted. The select protection schemes must also be given—these include procedures, work practices, emergency procedures, and personal protective equipment (PPE). Detai ls of the employer's HazCom program must also be addressed in the training. All of this is similar to the present requirements for training. Deadlines for completing this train- ing are as follows: t End user's employees must be trained by December 1, 2013. t Manufacturers, importers, distributors, and their employees must be trained by June 1, 2015. t No products can ship after December 1, 2015, unless they comply with the new labeling regulations. This time table may seem odd to some — especially the fact that end users must be trained before manufac- turers are required to be trained. OSHA understands what a monumental task retraining existing employees will be, as well as the reclassification system requirements. It anticipates a transition period during which the older label- ing system and MSDS will continue on already-produced products. During this transition, either or both systems may be used. Thus, end users must be trained first so they can be aware of each label- ing system that might be delivered from different vendors. Care must be taken in training under this new system. While all the information we have become accus- tomed to will still be there, a higher level of sophistication is inherent in the new system. Employees are expected to know the terminology used. For example, a new list of physical hazards may include pyrophoric substances. These are not new substances, but ones with an unfamiliar term. Pyrophoric substances are substances that ignite on exposure to air. That is it — just air. Previously, an MSDS might have listed them as f lammable and included precautions. Under the new system, they must be listed as "pyrophoric" and described as a liquid or a solid. The GHS also introduces a European concept in hazard recognition: sensitizers. Sensitizers are those chemicals that cause a lasting effect on tissue, making users even more susceptible or "sensitized" to the chemical on the next exposure. Painters are not new to this concept. In the future, any chemical components that are capable of sensitizing the skin or respiratory tract must be labeled as present. Previously, such chemicals were labeled as "irritants." This means that employees must also be trained as to what the terms mean and how they apply to them and their work. This is an impor tant concept under any training requirements of OSHA. Generic training is not enough. Employees must be trained to the specific hazards that an employer will exposure them to or may be exposed to in that workplace. This is a far higher burden then sending an employee to a class. Further, the training must include exact ly how the employees wi ll be protected by the employer's procedures and/or protective equipment. While the look and name of MSDS will change, the same information will be there. Perhaps, even a chance to raise the bar on our training and understand- ing of specif ic hazards. For further information, see osha.gov at: http:// www.osha.gov/dsg/hazcom/index.html. Information regarding specific require- ments and how they pertain to your area can be found by calling the area offices listed on this Web page: http://www. osha.gov/html/RAmap.html. The new Hazard Communication regulation is a big change. You must literally get with the safety program. CP July 2012 J www.coatingspromag.com 31