Hazard Communication and the Globally Harmonized System (GHS)

Goals for this session…

• Address common hazard communication violations…

• Understand major elements of hazard communication & global harmonization

• Answer your questions

Have you recently checked all the work and storage areas to ensure you have a comprehensive list of all of the chemicals at your site, including products brought to your site by contractors?

Does your hazard communication program identify the method you will use to inform employees of the hazards of non-routine tasks and procedures for sharing information with employees other than your own?

Have you checked this month to ensure all secondary containers are labeled with an appropriate hazard warning?

Do you have the ability to send a MSDS for a product [nox-rust (19)] to

the hospital with an injured employee?

Do you have evidence your employees have been trained on the health hazards of all of the chemicals they can smell at work?

Hazardous chemical 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

Products and chemicals not covered • Hazardous waste covered RCRA (EPA).

• Hazardous substances when it is the focus of remedial or removal action conducted under CERCLA (EPA)

• Tobacco or tobacco products.

• Wood or wood products

» treated wood and wood that is cut generating dust are not exempt

• Articles - not a fluid or particle in its end use that does not release hazardous chemicals and does not pose a health risk

• Food or alcohol sold in retail for personal consumption.

• Any drug defined by the Federal Food, Drug, and Cosmetic Act.

• Cosmetics for personal use.

• Any consumer product covered by the CPSC.

• Nuisance particulates that do not pose a physical or health hazard.

• Ionizing and nonionizing radiation.

• Biological hazards

Consumer Products • defined as such under the CP Safety Act • used as intended by the manufacturer • used with the same frequency and duration of a

typical consumer.

• Windex – Isopropanol & Ethyleneglycol Monohexylether » Flash point - 130°F

» sprayed onto glass for cleaning » Is the frequency and duration of exposure is greater than

a normal consumer?

No change to basic hazard communication program

• Management responsibility for program

• Develop list of hazardous chemicals

• Label hazardous chemical containers

• Manage Safety Data Sheets

• Procedures for training exposed employees

• Address the hazards of non-routine tasks

• Procedures for Multi-employer workplaces

Currently chemicals labeled with…

• Chemical identity

• Appropriate hazard warnings

• Name and address of the responsible party

The one, one, one rule.

• When a hazardous chemical is transferred into one container for the immediate use (one shift) by one employee, then the container does not have to be labeled.

• Any residual in the container must be immediately recycled or treated as waste.

Safety Data Sheets

• If SDS has been received for a hazardous chemical, employer must contact the supplier, manufacturer, or importer to obtain one and maintain a record of the contact

Safety Data Sheet • Accessible during each work shift.

• Must be in English

• Electronic access and alternatives to paper are permitted as long as barriers to access are not created.

Hazard Communication Training

• At the time of initial assignment

• Whenever a new hazard is introduced in the work area

Employee information

• The requirements of the standard.

• Operations in their work area where hazardous chemicals are present.

• The location and availability of the written program, hazardous chemical list, and material safety data sheets.

Employee training • Methods and observations used to detect a release of a

hazardous chemical (monitoring, odor, visual appearance)

• The physical and health hazards of chemicals in the work area.

• The measures employees can take to protect themselves (specific procedures, work practices, emergency procedures, and ppe)

• The details of the hazard communication program (labeling, SDS’s, and how to obtain and use the information.

Standard for a Globally Harmonized System of Classification and

Labeling of Chemicals

Development of Final Rule • NPRM Published in the Federal Register

on September 30, 2009 (74 FR 50280-50549).

• The final rule was published in the Federal Register on March 26, 2012 and became effective on May 25, 2012.

Why GHS? • Uniform information to communicate

chemical hazards for international trade

• 50,000 chronic illnesses in 1992 from occupational exposure to chemicals

• Could prevent 43 fatalities annually

In hazard communication 2012…

• Hazard classification: Provides specific criteria for classification of health and physical hazards

• Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal words, pictogram, and hazard statement for each hazard class and category.

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

• Information and training: The GHS requires workers be trained to understand the new labels and safety data sheets.

Organization of the Final Rule a) Purpose

b) Scope and Application

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

Appendices A–F

Appendices

• Appendix A, Health Hazard Criteria (Mandatory) (NEW)

• Appendix B, Physical Hazard Criteria (Mandatory) (NEW)

• Appendix C, Allocation of Label Elements (Mandatory) (NEW)

• Appendix D, Safety Data Sheets (Mandatory) (NEW)

• Appendix E, Definition of “Trade Secret” (Mandatory)

• Appendix F, Guidance for Hazard Classifications re: Carcinogenicity (Non-Mandatory) (NEW)

Important Dates Effective

Completion Date Requirement(s) Who

December 1, 2013

Train employees on the new label elements and SDS format.

Employers

June 1, 2015

Comply with all modified provisions of this final rule, except distributor extension

Chemical manufacturers, importers, distributors and employers

December 1, 2015

Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.

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

Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both.

All chemical manufacturers, importers, distributors and employers

Hazard Classification

Chemical 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

Use Appendix A for health hazard criteria and Appendix B for physical hazard criteria

10 health hazard categories and 16 physical hazard categories.

Health Hazard Classifications Hazard Class Hazard Category Acute 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 - Specific Target Organ Toxicity Single Exposure 1 2 3

STOT – Repeated Exposure 1 2

Aspiration 1

Simple Asphyxiants Single Category

Physical hazard classification Hazard 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

Training • Train employees on the new label elements

and SDS format by December 1 , 2013.

• Provide additional training for any newly identified physical or health hazards by June 1, 2016.

Labels • Pictograms

• signal words

• hazard and precautionary statements

• the product identifier

• supplier identification.

Other hazards which do not result in classification

• Combustible dusts

• OSHA includes dusts under its definition for hazardous chemicals, requiring that employers account for them on safety data sheets and in worker training.

• signal word “warning”

• hazard statement “may form combustible dust concentrations in air”

No more combustible liquids?

• Flammable liquids category 1, 2, 3 & 4

» No longer use 100 F – 23 C or 95 F

16-Section Safety Data Sheet 1. Identification of the substance

or mixture and of the supplier

2. Hazard(s) identification

3. Composition/information on ingredients

4. First aid measures

5. Firefighting measures

6. Accidental release measures

7. Handling and storage

8. Exposure controls/personal protection

9. Physical and chemical properties

10. Stability and reactivity

11. Toxicological

12. Ecological information (non mandatory)

13. Disposal considerations (non mandatory)

14. Transport information (non mandatory)

15. Regulatory information (non mandatory)

16. Other information including information on preparation and revision of the SDS

Appendix D • Specifies the minimum information to be

included in each of the 16 sections.

• Two revisions in the final rule:

» ACGIH TLVs continue to be required on the SDS.

» Information regarding carcinogenicity classifications by IARC and NTP also continue to be required.

To do list… • For Employers

» Review current hazard communication program and update yours to meet 2012 requirements

» Training on the label elements

» Training on new SDS format

» Start obtaining the updated SDSs

• For Manufacturers

» Start classification of products, develop new labels, update safety data sheets, help save lives or prevent disease.

A Guide to The Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

• http://www.osha.gov/dsg/hazcom/ghs.html