Hazard Communication

Brodie LoushinPayneWest

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The Purpose of the Hazard Communication Standard (HCS)

1. Reduce illness and injuries related to hazardous chemical exposures

2. Evaluate hazardous chemical usage and storage at our facilities

3. Communicate information to employees, emergency responders, and contractors about the hazardous chemicals used at, or brought into, our facilities

4. Reduce quantities of hazardous waste disposal fees due to unused products left at or past their prime use condition

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WORKPLACE CHEMICALSPut Everyone At Risk

Employees are exposed to hazardous chemicals everyday!

NIOSH research indicates that up to 50% of asthma patients have exacerbated pre-existing asthma through exposure to workplace chemicals.

Acute ExposureChronic Exposure

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Common Chemical Exposures

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Material Safety Data Sheets (MSDS) • Developed by Chemical manufacturers and

importers• Distributors transfer to customers • Includes information regarding hazards

associated with the product• Employers maintain a copy onsite

• Electronic or hard copies of MSDS must be reasonably available

• MSDS records must be maintained for 30 years after the product has been used.

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Required by law except for:◦ Food◦ Drugs◦ Cosmetics◦ Tobacco or tobacco products◦ Wood or wood products

Treated wood or wood intended for subsequent cutting/dust generation is not exempt

◦ Biological hazards◦ Nuisance particulates◦ Ionizing and non-ionizing radiation◦ Over the shelf products in quantities a consumer would have – AKA

one or two bottles◦ Hazardous waste covered by RCRA◦ Hazardous substances covered by CERCLA (removed/remediated

substances)

Material Safety Data Sheets (MSDS)

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Must include some basic information◦ Name, address and phone number of the manufacturer◦ Identity used on the label◦ Chemical and common name◦ Physical and chemical characteristics◦ Physical hazards◦ Primary route of entry◦ PEL/TLV◦ If it is a carcinogen◦ Safe handling procedures◦ Control measures◦ Emergency & first aid information◦ Date of preparation

MSDS

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Name, address and phone number of manufacturerIdentity use on the label

Chemical names of ingredients

Emergency and First Aid

Date of preparation

Carcinogen information

Physical Hazards

Primary route of entry

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PEL/TLV

Control measures

Safe handling precautions

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More control procedures

Physical/chemical characteristics

Environmental

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Labeling

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Beatty Gulch Tanks

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What does it all mean? Don’t swallow it

◦ If you do, don’t vomit Don’t spray it in your

eyes◦ If you do flush with water◦ Best to look at the direction

of the arrow on top of spray button

Don’t use in confined spaces without proper ventilation

Avoid skin contact◦ If you do, wash with soap

and water

It is flammable◦ Don’t store it by the furnace◦ Don’t spray it into the flames◦ Don’t let it touch the battery

terminals◦ An ABC extinguisher is fine to

extinguish a fire Leaking cans

◦ Put them in a bucket until pressure is dispersed

◦ Clean up any spills with pig pads

Store in flammable cabinet ◦ In vehicles care should be

taken to not store in direct sun and avoid temps over 120o

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Caution Consider how the manufacturer intended the

product to be used◦ Fertilizer used in small quantities is not harmful to

plants Consider the quantity of the product being used

◦ One can of WD-40 verses a facility where they are manufacturing the cans of WD-40

Consider the controls in place when using the product◦ Natural gas is a hazard when not controlled by design.

We cook our food and heat our homes safely when natural gas is controlled.

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Chemical inventory Hazard evaluation Communication of hazards to employees

and contractors Labeling of containers including piping

systems Training

Implementing Hazard Communication Programs

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Chemical Groups Solvents, Strippers, and Degreasers Paints, Coatings, and Resins Adhesives, Sealants, and Cement Pesticides, Insecticides and Herbicides Fuels and Fuel Additives Lubricants, Hydraulic and Cutting Fluids Cleaners and Detergents Compressed Gas Insulating Materials, Abrasives and Packing Corrosives Coolants Metals and Fluxes for Welding and Melting Other Chemicals and Specialty Chemicals Water Treatment Chemicals

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By reading the MSDS a hazard evaluation can take place based on the chemicals in the product and how it is used

Use the MSDSonline system to identify hazard warning labels on secondary containers

Monitoring can also be used to evaluate exposure risks

Hazard Evaluation

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Identification of chemical Warning labels Name and address of

manufacturer/distributor Legible In English Prominently displayed Secondary containers

Labeling

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Must be labeled unless◦ Immediately used by person making transfer◦ Under the control of the person making the transfer

Examples:◦ Transfer paint from a five gallon container to a quart

sized container for quick paint touch up activities Quart must be labeled unless product is used up at the

end of the workday or when not under the control of the employee who transferred it

◦ Transfer five gallons of oil from a 55 gallon barrel Five gallon container must be labeled

Secondary Containers

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Understand hazards of chemicals you are exposed to

Understand the MSDS Understand your responsibilities to

communicate hazards to others Understand your responsibilities to label

containers and piping systems Understand what is required on a label Understand the company’s electronic MSDS

system

Training

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BreakGHS next

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What is the GHS? GHS is a world-wide standardized approach to

hazard communication◦ supported by the United Nations and regulatory

agencies around the globe, including OSHA. GHS can be summarized into three main

components: ◦ Standardized hazardous chemical classifications◦ Standardized hazard warnings and symbols on

container labels◦ Standardized MSDS format and content (SDS)

Globally Harmonized System (GHS)

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What is the phase-in period? December 1, 2013: Employers required to train

employees on the new label elements and safety data sheet (SDS) format.

June 1, 2015: Chemical manufacturers, importers, distributors and employers required to be in compliance with all modified provisions of this final rule, except:

December 1, 2015: The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label

GHS Phase-in Period

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June 1, 2016: Employers required to update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

During the phase-in period, employers are required to be in compliance with either the existing Hazard Communication Standard (HCS) or the revised HCS, or both. ◦ OSHA recognizes there will be a period of time where labels and

SDSs under both standards will be present in the workplace. ◦ This will be considered acceptable, and employers are not

required to maintain two sets of labels and SDSs for compliance purposes.

GHS Phase-in Period cont’d

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Hazard classification: The current HCS is a performance-oriented approach that provides parameters for the evaluation, but not specific, detailed criteria. The revised HCS has specific criteria for each health and physical hazard, along with detailed instructions for hazard evaluation and determinations as to whether mixtures or substances are covered.

Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.

Safety Data Sheets: Will now have a specified 16-section format.

GHS: Three major areas of change

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Three main hazard classifications:◦ Physical Hazards◦ Health Hazards◦ Environmental Hazards

GHS: Hazard Classification

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Physical Hazards: Explosives Flammable Gases Flammable Aerosols Oxidizing Gases Gases Under Pressure Flammable Liquids Flammable Solids Self-Reactive

Substances Pyrophoric Liquids Pyrophoric Solids

GHS: Hazard Classification

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Self-Heating Substances Substances which, in

contact with water emit flammable gases

Oxidizing Liquids Oxidizing Solids Organic Peroxides Corrosive to Metals

Health Hazards◦ Acute Toxicity ◦ Skin Corrosion/Irritation ◦ Serious Eye Damage/Eye Irritation ◦ Respiratory or Skin Sensitization ◦ Germ Cell Mutagenicity ◦ Carcinogenicity ◦ Reproductive Toxicology ◦ Target Organ Systemic Toxicity - Single Exposure ◦ Target Organ Systemic Toxicity - Repeated Exposure ◦ Aspiration Toxicity

GHS: Hazard Classification

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Environmental Hazards◦ Hazardous to the Aquatic Environment

Acute aquatic toxicity Chronic aquatic toxicity

Bioaccumulation potential Rapid degradability

Environmental hazards are not within OSHA's jurisdiction

GHS: Hazard Classification

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How will labels change? Pictogram: a symbol plus other graphic elements, such as a border,

background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the HCS.

Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards.

Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. Example: Fatal if swallowed

Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical. Addresses prevention, response, storage, disposal.

GHS: Labels

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Prevention◦ Wash hands thoroughly after handling

Response◦ If swallowed: Immediately call a poison

center/doctor

Storage◦ Store in well-ventilated place. Keep cool.◦ Store locked up

Disposal◦ Dispose of content/container in accordance with

local/regional/national/international regulations

Precautionary Statement Examples

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Health Hazard Flame Exclamation Mark

• Carcinogen• Mutagenicity• Reproductive Toxicity• Respiratory Sensitizer• Target Organ Toxicity• Aspiration Toxicity

• Flammables• Pyrophorics• Self-Heating• Emits Flammable Gas• Self-Reactives• Organic Peroxides

• Irritant (skin and eye)• Skin Sensitizer• Acute Toxicity (harmful)• Narcotic Effects• Respiratory Tract Irritant• Hazardous to Ozone

Layer (Non Mandatory) Gas Cylinder Corrosion Exploding Bomb

• Gases under Pressure • Skin Corrosion/burns• Eye Damage• Corrosive to Metals

• Explosives• Self-Reactives• Organic Peroxides

Flame over Circle Environment(Non Mandatory)

Skull and Crossbones

• Oxidizers • Aquatic Toxicity • Acute Toxicity (fatal or toxic)

GHS: Label Pictograms

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Q. Can I use a black border on pictograms for domestic shipment?

A. Under the revised Hazard Communication Standard (HCS), pictograms must have red borders. ◦ OSHA believes that the use of the red frame will increase

recognition and comprehensibility. Therefore, the red frame is required regardless of whether the shipment is domestic or international.

GHS: Labels

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Q. Will OSHA allow blank red borders?

A. The revised HCS requires that all red borders printed on the label have a symbol printed inside it. ◦ If OSHA were to allow blank red borders, workers may be

confused about what they mean and concerned that some information is missing.

◦ OSHA has determined that prohibiting the use of blank red borders on labels is necessary to provide the maximum recognition and impact of warning labels and to ensure that users do not get desensitized to the warnings placed on labels.

GHS: Labels

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Q. When must label information be updated? A. In the revised HCS, OSHA is lifting the stay on

enforcement regarding the provision to update labels when new information on hazards becomes available. ◦ Chemical manufacturers, importers, distributors, or employers

who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information.

◦ If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.

GHS: Labels

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Q. How will workplace labeling provisions be changing under the revised Hazard Communication Standard?

A. The current standard provides employers with flexibility regarding the type of system to be used in their workplaces and OSHA has retained that flexibility in the revised HCS.◦ Employers may choose to label workplace containers either with

the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard.

◦ Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent

with the revised HCS, e.g., no conflicting hazard warnings or pictograms.

GHS: Labels

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The format of the 16-section SDS should include the following sections:◦ 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

GHS: Safety Data Sheet (SDS)

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Questions?

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Hazard Communication QuizQuestion 1

How can you access a MSDS for a product?

A. Notebook on Shelf B. Internet C. Safety Specialist D. All of the above

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Hazard Communication QuizQuestion 2

Why should containers be labeled?

A. It is a regulatory requirementB. They look niceC. Everyone will know what it containsD. A and C

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Hazard Communication QuizQuestion 3

What is the most common chemical that you are potentially exposed to on the job?

A. OilB. Welding fumeC. MethaneD. Solvent

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Question 4

True or False1. A label must be legible.2. The manufacturer’s name and address

must be on the secondary container label.3. Piping systems are exempt from the

Hazard Communication Standard.

Hazard Communication Quiz

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Question 5

True or False1. The GHS is a world-wide standardized approach to

hazard communication.2. The GHS stands for Globally Harmed Situation.3. The GHS will standardize hazardous chemical

classifications. 4. The GHS will standardize hazard warnings and

symbols on container labels.5. The MSDS format and content will not change.

Hazard Communication Quiz

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Question 6

During the GHS phase-in period, what is required to be completed by: ◦ December 1, 2013◦ June 1, 2015◦ December 1, 2015◦ June 2, 2016

Hazard Communication Quiz

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Question 7 Can I use a black border on pictograms for

domestic shipment?

Question 8 Will OSHA allow blank red borders?

Question 9 How many sections are required for the SDS?

Hazard Communication Quiz

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Match the Pictogram to the appropriate title

Hazard Communication Quiz

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1. _____ a. Irritant

2. _____ b. Flammable

3. _____ c. Compressed Gases

4. _____ d. Corrosive

5. _____ e. Health Hazard

6. _____ f. Acute Toxicity

7. _____ g. Environmental Hazards

8. _____ h. Oxidizer

9. _____ i. Explosives

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