GHS HAZARD COMMUNICATION

James.elder@lubrizol.com

June 17, 2013

Have you started using any GHS elements in your Hazard Communication training?

A •Yes

B •No

C•Don’t know what GHS is

Overview

Purpose Definitions GHS Changes Pictograms

OSHA 1910.1200 Standard

Several states enacted their own “Right to Know” law

Chemical manufacturers wanted one uniform law vs. various state laws

1910.1200 Ordered by Congress -1985 Global Harmonization Standard (GHS)

added in 2012

The Problem 4,609 fatal work injuries were recorded in

the United States in 2011, 4,690 fatal work injuries in 2010 And work-related illnesses cause about

49,000 deaths each year, according to the CDC.

You have a right to know the hazards of chemicals in the workplace.

Purpose

To ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards are transmitted to employers and employees.

Accomplished with:- container labeling- material safety data sheets - employee training

Outline of Standard(a) Purpose(b) Scope(c) Definitions(d) Hazard Classification(e) Written Hazard Communication Program(f) Labels and Other Forms of Warning(g) Safety Data Sheets(h) Employee Information and Training(i) Trade Secrets(j) Effective Dates(k) Other Standards Affected(l) Appendices

Definitions

Terms no longer being defined due to changes in terminology: Hazard warning; identity; and material safety

data sheet (MSDS)Terms revised to be consistent with the

GHS:Chemical; chemical name; hazardous chemical;

health hazard; label; mixture; physical hazard; and trade secret

Definitions

The following terms are being added to the definitions section:Classification; hazard category; hazard class;

hazard not otherwise classified; hazard statement; label elements; pictogram; precautionary statement; product identifier; pyrophoric gas; safety data sheet (SDS); signal word; simple asphyxiant; and substance

Definitions

“Chemical”OSHA previously used “chemical” to indicate both

substances and mixturesOSHA has decided to continue using “chemical” in the

final rule as meaning those situations where both substances and mixtures are being addressed

“Hazardous chemical” means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified

Definitions

“Hazards Not Otherwise Classified”Classified identifies a hazard, but the evidence does not

meet the currently specified criteria covered by Haz Com 2012

Example: Static Accumulator, Magnetic, etc.Information will be required on the safety data sheets in

Section 2Hazard information on the label, is not mandatory, but

can be provided under supplementary informationSuch hazards must also be addressed in worker training

Definitions

“Precautionary statement” means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling. For example: Wear face protection [for

Explosives, Division 1.1]

(d) Hazard Classification

Each type of hazard covered is considered a “hazard class”—such as acute toxicity, carcinogenicity

However, most of these hazard classes are also sub-divided into “hazard categories” to reflect the degree of severity of the effect

This is the concept of “classification”—rather than just determining that there is a hazardous effect (carcinogenicity), there is also a finding of how severe that effect might be (Category 1 or 2)

(d) Hazard Classification

Classification ProvisionsChemical manufacturers and importers must

classify each chemical they produce or import: Determine the appropriate hazard classes and associated

hazard categories Base this on an evaluation of the full range of available

data/evidence on the chemical (no testing is required) Use Appendix A for health hazard criteria and Appendix B

for physical hazard criteria The introduction to Appendix A provides the general

approach to classification, including bridging principles

Health Hazards Classifications

Hazard Class Hazard CategoryAcute Toxicity 1 2 3 4

Skin Corrosion/Irritation 1A 1B 1C 2

Serious Eye Damage/ Eye Irritation

1 2A 2B

Respiratory or Skin Sensitization 1

Germ Cell Mutagenicity 1A 1B 2

Carcinogenicity 1A 1B 2

Reproductive Toxicity 1A 1B 2 Lactation

STOT –Single Exposure 1 2 3

STOT – Repeated Exposure 1 2

Aspiration 1

Simple Asphyxiants Single Category

Physical HazardsHazard Class Hazard Category Explosives Unstable

Explosives Div 1.1 Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6

Flammable Gases 1 2 Flammable Aerosols 1 2 Oxidizing Gases 1 Gases under Pressure Compressed Gases Liquefied Gases Refrigerated Liquefied Gases Dissolved Gases

1

Flammable Liquids 1 2 3 4 Self-Reactive Chemicals Type A Type B Type C Type D Type E Type F Type G Pyrophoric Liquids 1 Pyrophoric Solid 1 Pyrophoric Gases Single

category

Self-heating Chemicals 1 2 Chemicals, which in contact with water, emit flammable gases

1 2 3

Oxidizing Liquids 1 2 3 Oxidizing Solids 1 2 3 Organic Peroxides Type A Type B Type C Type D Type E Type F Type G Corrosive to Metals 1 Combustible Dusts Single

Category

(e) Program Requirements Written program List of all hazardous chemicals Must Address all non-routine tasks Discuss and update contractor

responsibilities SDS (Safety Data Sheets) must be

available upon request to any employee or contractor

(e) Written Program

Must describes how the standard will be implemented in your facility  

Must contains a list of all chemicals within facility

(f) Labels

Required Elements Product identifierSignal words Hazard statements Pictograms Precautionary statements Name, address, and telephone number of the

chemical manufacturer, importer, or other responsible party

A new Appendix C, Allocation of Label Elements, has been provided to indicate the label requirements by hazard class and category

Labels are to be updated within 6 months of getting new and significant information about the hazards, or ways to protect those exposed

(f) Labels

OSHA is maintaining the current approach to allowing alternatives to labels on each stationary process container

The exception for portable containers under the control of the person who filled them with the chemical remains the same.

Labels on incoming containers are not to be removed or defaced unless immediately replaced by another label

Workplace labels are to be prominently displayed and in English, although other languages are permitted as well

Pictograms

(f) Labels Example

HS85

WarningBatch number: 85L6543Harmful if swallowed. Wash hands and face thoroughly after

handling. Do not eat, drink or smoke when using this product. Dispose of contents/container in accordance with local, state and federal regulations.

First aid: If swallowed: Call a doctor, Rinse mouth.

GHS Example Company, 123 Global Circle, Anyville, NY 130XX

Emergency Telephone (888) 888-8888

(f) Labels Sample HS85 Label

(f) Labels

Employers are responsible for maintaining the labels on the containers, including, but not limited to, tanks, totes, drums, and for training their employees on the hazards listed on the labels in the workplace.

Labels must continue to be: legible contain the pertinent information (such as the

hazards and directions for use) not able to be defaced, (i.e., fade, get washed

off,) or removed in any way as stated in revised Hazard Communication Standard, 29 CFR 1910.1200(f)(9)

(g) Safety Data Sheets (SDS)

The GHS uses a specified order of information, as well as title descriptions, on the 16-section safety data sheet.

Health, physical and environmental hazard criteria for substances and for classification of mixtures.

Consistent with voluntary industry consensus standards, such as ANSI.

Should improve comprehensibility and issues regarding accuracy of information.

(g) Safety Data Sheet (SDS) Format

1. Identification of the substance or mixture and of the supplier

2. Hazards identification3. Composition/

information on ingredients

4. First-aid measures 5. Fire-fighting

measures6. Accidental release

measures7. Handling and storage

8. Exposure controls/personal protection

9. Physical and chemical properties10. Stability and reactivity11. Toxicological information12. Ecological information

(non-mandatory)13. Disposal considerations

(non-mandatory)14. Transport information

(non-mandatory)15. Regulatory information

(non-mandatory)16. Other information,

including date of preparation or

last revision  

(g) Safety Data Sheets (SDS)

SDS in the workplace for each hazardous chemical which is used

OSHA requires these forms for each hazardous chemicals

Readily accessible during each work shift to employees when they are in their work area(s)

(g) Safety Data Sheets (SDS) Identifies chemicals by name Tells potential harm and how chemicals

will enter the body (Inhalation, ingestion, and/or skin absorption)

Explains signs and symptoms of exposures

Explains emergency procedures

(h) Employee Training

Although this paragraph remains essentially the same, updates include Training to include label elements and new

safety data sheet format - by December 1, 2013

Training to reflect any new hazards identified in the workplace - by June 1, 2016

Training – prescribed label elements and order of information on data sheets facilitate training/comprehensibility.

(h) Employee Training Trained initially and

when new chemical introduced

OSHA standard covered

Operations in their work area where chemical is used

Pictograms

Location of program, list of chemical, and SDS

Detection of chemical

Hazards of chemical

Protection measures

Emergency procedures

Labeling system used

Temporary Employees

The temporary agency employer would provide generic hazard training and information concerning categories of chemicals employees may potentially encounter

Host employers would then be responsible for providing site-specific hazard training pursuant to sections 1910.1200(h)(1)

Compliance Issues

Can your employees retrieve information stored on a computer?

If you have employees who speak a language other than English how do you ensure that these employees understand your labels, what about your foreign customers i.e. non EU.

Who puts labels on portable containers?

More Issues How is the outside contractor informed of

chemicals in the area? What do you do if the label falls off an old

container? How is chemical piping labeled? What chemicals do I have that may

contain cancer causing chemicals?

FLAMMABLE LIQUIDS(Classified in Accordance with Appendix B.6)

      PictogramFlame

Hazard category

Signalword

Hazard statement

1 Danger Extremely flammable liquid and vapor (old

1A)2 Danger Highly flammable liquid

and vapor (old 1B)3 Warning Flammable liquid and

vapor    Pictogram

No PictogramHazard

categorySignal word

Hazard statement  

4 Warning Combustible liquid

Revision of 29 CFR 1910.106 Flammable Liquids

Flammable liquids are divided into four categories as follows:

(i) Category 1 . . . FPs below 73.4 o F (23 o C) and having a BP at or below 95 o F (35 o C).

(ii) Category 2 . . . FPs below 73.4 o F (23 o C) and BP above 95 o F (35 o C). This was the old IB

(iii) Category 3 . . . FPs at or above 73.4 o F (23 o

C) and at or below 140 o F (60 o C). (iv) Category 4 . . . FPs above 140 o F (60 o C) and

at or below 199.4 o F (93 o C).

Revision of 29 CFR 1910.106 Flammable Liquids

GHS Flammable and Combustible Liquids Standard (29 CFR 1910.106)

Category Flashpoint ºC (°F) BoilingPoint ºC (°F)

Class Flashpoint ºC (°F) Boiling PointºC (°F)

Flammable 1 < 23 (73.4) ≤ 35 (95) Flammable Class IA < 22.8 (73) < 37.8 (100)

Flammable 2 < 23 (73.4) > 35 (95) Flammable Class IB < 22.8 (73) ≥ 37.8 (100)

Flammable 3 ≥ 23 (73.4) and ≤ 60 (140)

Flammable Class IC Combustible Class II

≥ 22.8 (73) and < 37.8 (100)

≥ 37.8 (100) and < 60 (140)

Flammable 4 > 60 (140) and ≤93 (199.4)

Combustible Class IIIA ≥ 60 (140) and <93.3 (200)

None Combustible Class IIIB ≥ 93.3 (200)

** Not covered by §1910.1200 or §1910.106 however interpretation letter indicates these are covered by §1910.107

Safety StandardsFlammable Liquids 1910.106

HCS 1994Flame arresters or venting devices required in subdivision (f) of this subdivision may be omitted for Class IB and IC liquids where conditions are such that their use may, in case of obstruction, result in tank damage.

HCS 2012(g) Flame arresters or venting devices required in paragraph (B)(2)(iv)(f) of this section may be omitted for Category 2 flammable liquids and Category 3 flammable liquids with a flashpoint below 100 °F (37.8 °C) where conditions are such that their use may, in case of obstruction, result in tank damage.

A good reference https://www.osha.gov/dsg/hazcom/side-by-side.html

Safety StandardsPSM 1910.119(a)(1)(ii)

HCS 1994A process which involves a flammable liquid or gas (as defined in 1910.1200(c) of this part) on site in one location, in a quantity of 10,000 pounds (4535.9 kg).

HCS 2012

A process which involves a Category 1 flammable gas (as defined in 1910.1200 (c)) or a flammable liquid with a flashpoint below 100 °F (37.8 °C) on site in one location, in a quantity of 10,000 pounds (4535.9 kg)

(j) Effective Dates

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