Introduction

Chemicals and pesticides are used globally by a multitude of workforces from many different cultures. The problem is that varying chemical and pesticide hazard ratings between companies and industries can lead to confusion and incidents. In an effort to standardize processes and prevent miscommunications, OSHA is integrating the global Health System (GHS) into the existing HAZCOM 1920.1200 standard (HCS).

Who Is Required to Comply With These New Changes?

These changes have the potential to affect numerous industries in varying ways, including those regulated by the Environmental Protection Agency (EPA), Department of Transportation (DOT), National Fire Protection Association (NFPA), Consumer Products Safety Commission (CPSC), and the American Coatings Association (ACA).

Many of these entities are working together to come up with solutions to ensure a smooth transition, and understanding of the changes and differences in order to prevent further confusion and aid in the overall goals of reducing incidents related to chemicals, pesticides and "other stuff".

It is important to note HCS does not apply to "agricultural" businesses (NAICS starting with 11), but does apply to Ag related manufacturers (i.e. sugar cane processing plant, citrus juicing plant, etc.). The Environmental Protection Agency (EPA) regulates businesses who apply pesticides under the Worker Protection Standard (WPS), and defines pesticide hazards and requirements through the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) via pesticide labels.

The intent of this report is to elaborate on the approaches of the entities listed above, along with the similarities and differences between them, while providing valuable tools and resources that can be utilized by varying businesses to help implement necessary changes throughout their organizations.

Differences Between Pesticides, Chemicals, and "Other Stuff"

Pesticides are any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest. Pests can be insects, mice and other animals, unwanted plants (weeds), fungi, or microorganisms like bacteria and viruses. Though often misunderstood to refer only to insecticides, the term pesticide also applies to herbicides, fungicides, and various other substances used to control pests. Under United States law, a pesticide is also any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant. A pesticide will have an "Ag Use box" on its application label.

It should be noted, there are pesticides that are NOT regulated for AG use (i.e. Remedy, bleach, etc.), which would be classified as a Chemical under OSHA's HCS, but not as a pesticide under EPA's WPS.

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