Whether your focus is import, export or use in the United States, our translation and interpreting services help you improve communication and avoid workplace injuries, lawsuits and regulatory fines.
Whatever the language of your employees, our professional translation and interpreting services can help you communicate important hazard and safety information to your employees in the language they understand.
Our Hazard Communication Standard translation services help you comply with worldwide regulations and avoid regulatory sanctions and fines.
We use our network of native language hazard and chemical industry experts with real work experience, not just translation experience to translate your HCS projects. All our translators are required to have an advanced degree, professional work experience and a minimum of 7 years translating relevant content.
We use a three-step validation process of translation, editing and proofing by three different ASKnetworkTM specialists to ensure multiple qualified professionals review all your content for accuracy.
Leverage Our Translation Memory for HCS Translation Projects
Typical HCS documents have a high rate of repetition. For example, up to 75% of the material in your SDS may be repetitive. We leverage translation memory to maintain consistency throughout your HCS translation projects while reducing translation turnaround times and costs.
Under the revised HCS standards, employers are required to train workers by December 1, 2013 on the new HCS labels (including the four elements of these labels) and on the updated Safety Data Sheet format. Employers are subsequently required to provide training two years after the final revised HCS is published, and then again by June 1, 2016 for any newly identified physical or health standards.
Our interpreters are also subject matter experts, experienced in communicating Hazard Communication Standard information for trainings. We take great care to match the technical background of the interpreters with your specific technical field.
We have an unsurpassed network of Scientific and Technical Interpreters providing both consecutive and simultaneous interpreting services worldwide. We have the resources and the experience to manage your project smoothly and ensure that information is conveyed accurately and appropriately.
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About The Revised Hazard Communication Standard
The Hazard Communication Standard was first established in 1983 to give both employers and those who work for them access to information about the chemicals they work with. Originally HCS was based on performance, letting chemical manufacturers and importers give chemical and safety information in any format they chose.
The revised HCS standardizes this information to eliminate confusion. The revised Hazard Communication Standard will make access to chemical hazard information more quick and efficient for employers, workers, first responders and health healthcare professionals. These standards will also make it easier for employers and workers to understand the hazards related to the chemicals they handle and should encourage more appropriate and safe use of chemicals in the workplace.
The revised Hazard Communication Standard (HazCom 2012) requires employers disclose toxic and hazardous substances, to provide employees with unrestricted access to Safety Data Sheets (formerly referred to as Material Safety Data Sheets), and to provide health and safety training so employees understand risks. The revised HCS is established in 29 CFR 1910.1200.
Under HCS, chemical manufacturers and importers must evaluate the chemicals and associated hazards and prepare suitable labels and Safety Data Sheets. Additionally, employers must use labels and make SDS available to employees and train all exposed workers to understand the labels, SDSs and how to work with the related chemicals.
Updates to the revised Hazard Communication Standard include
- Establishment of specific criteria for classifications of mixtures and for health and physical standards
- Requirement for both chemical manufacturers and importers to provide a label with four specific elements
- Updated format for Safety Data Sheets to comply with the GHS
- Training requirement for employers to train employees in recognizing and understanding the new labels and SDS formats
For the most part the revised HCS does not make major changes, but rather just modifies the current HCS to bring it into compliance with GHS. Some terms have been changed to reflect the GHS such as “hazard determination” becoming “hazard classification” and “Material Safety Data Sheet (MSDS)” becoming “Safety Data Sheet (SDS).” Otherwise, the basic framework, scope and exemptions of the HCS stay the same.
Revised HCS Under The Global Harmonization Standard
The Hazard Communication Standard was revised to bring it into compliance with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). GHS gives a standard approach with specific criteria for the hazardous effects that chemicals can cause and specific standards for labels for hazard classes and categories. It also helps all interested parties (employers, employees, healthcare and emergency professionals) to quickly and efficiently get chemical information when needed.
The Global Harmonization Standard (GHS) is the result of an international approach to hazard communication. It standardizes hazard labels and warnings to eliminate confusion. GHS comes from an internationally negotiated report produced by hazard communication experts around the world, international organizations and interested groups. This report is also sometimes referred to as “The Purple Book.”
The GHS establishes an agreed upon standard for classifying chemical (as well as health and physical) hazards, for label elements and for safety data sheets. This harmonized standard will reduce trade barriers and make it easier for companies both internationally and within the United States that contact toxic and hazardous chemicals and materials in their business operations.
Using the GHS for standards in the United States and globally will improve global communication and provide consistent information. Currently as chemicals are imported and exported worldwide workers come in contact with a variety of labels and safety data sheets that may or may not be understood. Companies also must follow different and even conflicting national and international regulations. Labels created for a chemical in one country may be incorrect or non-compliant in another country. Bringing the Hazard Communication Standard under the GHS cuts through the confusion and help workers understand the labels for hazardous chemicals they work with.
Requirements Under Revised Harmonized HCS
Hazard Communication Standard Label Requirements
Under the revised harmonized HCS, all labels must include a signal word, a pictogram, hazard statement for each hazard class and category, and precautionary (warning) statements.
4 Elements To Revised HCS Labels
1. Signal Word:
Signal words such as “warning” or “danger” denote how serious the hazard is, with warning being less severe than danger.
The pictogram has a designated symbol on a white background with a red diamond square border. Pictograms must have a red frame whether for domestic or for international shipments (no more black borders). Also, using a blank red border is prohibited to avoid confusion. The Global Harmonized Standard has 9 total pictograms for health, physical and environmental hazards, with 8 of these required under the HCS (The GHS includes a pictogram for environmental hazards that are not part of the revised HCS).
3. Hazard Statement:
Each hazard class and category has a designated statement describing the type of hazard, where it is suitable and the degree of hazard. These classes and categories are set by the revised HCS to indicate the type and severity of the hazard. The revised HCS gives directions for evaluating hazards, verifying if mixtures or substances are covered, and then denotes specific criteria for each health and physical hazard.
4. Precautionary Statement:
This statement gives recommendations for how to reduce or prevent adverse effects from exposure to a hazardous chemical or from not properly storing or handling that chemical.
Under the revised Hazard Communication Standard, employers can choose to use the same labels as for shipping containers or alternative labels so long as they have the information required under the revised HCS with no conflicting warnings or pictograms. For example, employers may choose to use the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) labels for workplace containers.
HCS Pictograms and Hazards (taken from https://www.osha.gov/dsg/hazcom/hazcom-faq.html)
|Health Hazard||Flame||Exclamation Mark|
Target Organ Toxicity
Emits Flammable Gas
|Irritant (skin and eye)
Acute Toxicity (harmful)
Respiratory Tract Irritant
Hazardous to Ozone Layer
|Gases under Pressure||Skin Corrosion/ burns
Corrosive to Metals
|Flame over Circle||Environment(Non Mandatory)||Skull and Crossbones|
|Oxidizers||Aquatic Toxicity||Acute Toxicity (fatal or toxic)|
Safety Data Sheet (SDS) Requirements
Safety Data Sheets will now have a specified 16-section format, although the headings for sections 12-15 will not be enforced by OSHA (these sections are outside of OSHA’s jurisdiction). Information that must be included on Safety Data Sheets is the same as the current HCS standard (HazCom 1994), but the revised HCS requires specific section headings in a specific order.
The 16-section format for all SDS under HCS must include
- Section 1. Identification
- Section 2. Hazard(s) identification
- Section 3. Composition/information on ingredients
- Section 4. First-Aid measures
- Section 5. Fire-fighting measures
- Section 6. Accidental release measures
- Section 7. Handling and storage
- Section 8. Exposure controls/personal protection
- Section 9. Physical and chemical properties
- Section 10. Stability and reactivity
- Section 11. Toxicological information
- Section 12. Ecological information
- Section 13. Disposal considerations
- Section 14. Transport information
- Section 15. Regulatory information
- Section 16. Other information, including date of preparation or last revision
Although under the revised HCS, all Safety Data Sheets must include sections 12 to 15, OSHA will not enforce what is under these headings because it is under the authority of other governmental agencies.
According to GHS recommendations, HNOC hazards are not required to be disclosed on the labels, but must be disclosed in section 2 of the Safety Data Sheet.
Under the revised Hazard Communication Standard, the American Conference of Government Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), OSHA permissible exposure limits (PELs), and all other recommended exposure limits recommended by chemical manufacturers, importers or employers are required on Safety Data Sheets
If a chemical is listed as a carcinogen by the International Agency for Research on Cancer (IARC) or the National Toxicology Program (NTP) then it must be included on the Safety Data Sheet. All IARC and NTP classifications are still required on Safety Data Sheets under the revised Hazardous Communication Standard.
The revised Hazard Communication Standard includes a separate category of “Hazards Not Otherwise Classified (HNOC)” that is not covered under the Global Harmonization Standard. These hazards are not required for labels, but must be included in Section 2 of the Safety Data Sheets.
Pyrophoric, simple asphyxiants and combustible dust are not part of the HNOC category, but fall under the “Hazardous Chemicals” category. Polyphoric gasses will still be defined as they are in the current HCS, and must be included in labels and Safety Data Sheets. Further, they must say “Danger catches fire spontaneously if exposed to air.” The definition of simple asphyxiants has been updated and these are required to be labeled and included on Safety Data Sheets when relevant. The label must say “Warning may displace oxygen and cause rapid suffocation.” Combustible dust is defined through the Combustible Dust National Emphasis Program Directive CPL 03-00-008 and other voluntary industry standards, such as the NFPA. Combustible dust must be labeled and included on Safety Data Sheets. The label must say “Warning may form combustible concentrations in the air.”
Who Oversees the Hazard Communication Standards
The Hazard Communication Standard were established in the by the Occupational Safety and Health Administration (OSHA). Canada uses the Workplace Hazardous Materials Information System, and the European Union uses the European Agency for Safety and Health at Work.
OSHA requires importers and chemical manufacturers to assess the hazards of the chemical they manage and to properly apply labels and create appropriate safety data sheets to communicate these hazards and accompanying information. OSHA also requires employers to make labels and safety data sheets available to exposed workers and to train them in proper chemical handling.
Revised Hazard Communication Standard Implementation Timeline
Full compliance with the revised Hazard Communication Standard must be in effect by 2015.
By December 1, 2013, employers are required to train workers on the new labels and Safety Data Sheet format to ensure that all exposed employees can recognize and understand the labels and procedures. This training must be complete by December 1, 2013 to make provisions for new labels and Safety Data Sheets that may be encountered before the law goes into full effect.
The revised HCS also mandates that all workers be retrained by two years after the final rule is published.
On June 1, 2015, the EU will implement their classification of mixtures. By December 1, 2015, all chemical manufacturers, importers distributors and employers must comply with the revised Hazard Communication Standard. However, distributors cannot ship containers with the chemical manufacturer’s label, except if it is a GHS label.
By June 1, 2016, employers must update their workplace labels and hazard communication program. By this date employers must also give employees additional training on newly identified physical or health standards.
While the revised Hazard Communication Standard are being phased in, organizations and employers must comply with the current HCS or the revised HCS or both. During this transition, there may be labels and Safety Data Sheets that are under both standards within the same workplace.
When the revised Hazard Communication Standard goes into effect, all labels for a chemical must be updated within six months of when manufacturers, importers, distributors or employers become aware of new information regarding that chemical.
In keeping with Global Harmonization Standards that the United Nations revises every two years, the revised Hazard Communication Standard will follow these GHS updates and be updated consistently.
For a chart on the revised Hazard Communication Standard implementation timeline see below (taken from https://www.osha.gov/dsg/hazcom/hazcom-faq.html)
|Effective Completion Date||Requirement(s)||Who|
|December 1, 2013||Train employees on the new label elements and safety data sheet (SDS) format.||Employers|
|June 1, 2015*
December 1, 2015
|Compliance with all modified provisions of this final rule, except:The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label||Chemical manufacturers, importers, distributors and employers|
|June 1, 2016||Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.||Employers|
|Transition Period to the effective completion dates noted above||May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both||Chemical manufacturers, importers, distributors, and employers|
*This date coincides with the EU implementation date for classification of mixtures
Revised Hazard Communication Standard Benefits
The revised HCS standards will eliminate confusion that comes from the many and varied local, national and international regulations and requirements for managing with hazardous chemicals. It helps users quickly and efficiently find and understand hazard information and keeps that information consistent across all countries and locations.
OSHA highlights anticipated productivity benefits as follows.
- Chemical manufacturers will have fewer Safety Data Sheets to produce
- Employers will be able to provide more efficient standardized training to employees on improved consistent labels and safety data sheets
- Organizations involved in international trade will have more consistent and less ambiguous standards to comply with
To see a comparison of the current and final revised Hazard Communication Standard, please see OSHA’s hazard communication safety and health topics webpage.
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