Hazard Communication Subpart Z 1910.1200

Toxic and Hazardous Substances

Presented byBetty DunbarDelaware Department of Labor Office of Occupational Safety and Health

Hazard Communication Subpart Z 1910.1200

Toxic and Hazardous Substances

• What does this mean to ME?

• How does this affect ME?

What is GHS??

Hazard Communication 1910.1200 • Purpose: (a)(1) To ensure that the hazards

of all chemicals are evaluated, and that information is transmitted to employers and employees.

Hazard Communication

Program

Container Labeling

Material SafetyData Sheet

M.S.D.S.

ProgramLabel

S.D.S.

Safety Data Sheet

Training Must Include:

• The Physical and Health Hazards of the chemicals one works with

• How you can tell you’ve been exposed to a chemical

• How you can protect yourself from the chemical

• How you can find the information needed yourself

• The Hazards Communication Program must include yearly training which provides employees information on dealing with the hazardous chemicals with which they work

• This must include the location of MSDS sheets (SDS sheets) and dangers of specific categories of hazards

Requires

Requires

• Each label to include:• 1) Product Name• 2) A warning statement, message or symbol

(hazard statement)• 3) Precautionary statement• 4) Harmonized signal word• 5) Pictogram• 6) Name and address of manufacturer

Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

• It is a system for standardizing and harmonizing the classification and labeling of chemicals.

• GHS is not a regulation or a standard • The UN adopted GHS in 2003• The US (OSHA) officially adopted GHS March 26, 2012 But6/1/2015 is the full compliance date in the US

Employees should have been trained in the elements of the new system

In transition either system may be used.

GHS has fixed, coded precautionary and hazardstatements

Labels will change under GHS

• The Signal Word - Danger or

Warning

• GHS Pictogram

• Precautionary Statement(since there are fixed codes for these – P222 will alwaysmean – “Do not allow contact with air”)

NFPA Diamonds

Blue = Health Red =

Flammability Yellow = Stability White = Special

hazard information

NFPA Diamonds

4= Deadly Hazard 3= Severe Hazard 2= Moderate

Hazard 1= Slight Hazard 0= No Hazard

HMIS Label

Differences in the Labels

• 1) NFPA is meant primarily for firefighters and emergency workers

• 2) HMIS system will show 2 boxes in blue area – one with a * if substance presents a chronic health hazard

• 3) HMIS system has a coding system for PPE required

NFPA and HMIS are voluntary systems

Comparison of Label Elements

HMIS Label Element

NFPA Label Element

GHS Label Element

OSHA is the Law !(Numbers from new and old regulation)

(or don’t panic if GHS and NFPA numbers are different – it is supposed to be that way!)

Flammability Criteria GHS NFPA HMIS

Flash point < 73oF (23oC) and initial boiling point < 100oF (37.8oC)

1 or 2 4 4

Flash point < 73oF (23oC) and initial boiling point > 100oF (37.8oC) and Flash point > 73oF(23oC) and 100oF (37.8oC)

2 or 3 3 3

Flash point > 100o F (37.8oC) and < 200oF(93.4oC)

3 or 4 2 2

Flash point >200oF(93.4oC) and will burn in air when exposed to a temperature of 1500oF(815.5oC) for a period of 5 min.

None 1 1

Sample Label

What will happen here??

• The GHS numbers are not intended for the labels

• NFPA and HMIS both are balking at changing their systems (we were here 1st!)

• Chemical manufacturers and importers may continue to use the systems they are currently using (as long as they make the additions required)

Will not be required by OSHA

GHS Pictograms

Health RelatedToxic

Health Hazard

Corrosive to Skin

Irritant

GHS PictogramsFlammable

Compressed Gas Cylinder

Corrosive to MetalExplosive

Oxidizer

Labeling of Secondary Containers

1)Secondary containers must be labeled in the same manner as primary containers:

a)Product Identifierb)Signal Wordc)Hazard Statement(s)d)Pictogram(s)e)Name, address, and telephone number of

chemical manufacturer, importer, or other responsible party

(A secondary container is one that is not the original container)

Practical Accommodation for Very Small Containers

As a practical accommodation OSHA will allow small containers to be labeled with:1) Product identifier;2) Appropriate pictograms;3) Signal Word;4) Manufacturer’s name and phone number; and5) A statement that full label information is on the outside

package.

The outside packaging must contain the information above plus the other required label information. The small container must be stored in the outside packaging (this direction should be on both small container and outside package)

M.S.D.S.(S.D.S)

• MSDS sheets must be available for employees to consult at all times

• Employees must be trained

Initially and whenever a new material is introduced into the workplace

(If you have a chemical and it’s MSDS before 6/1/2015 – you do not need to replace it until you order it again)

MSDS’s must include:

1. Product identity & ingredients

2. Physical and chemical characteristics

3. Fire and explosion hazards

4. Reactivity information

5. Health hazards; symptoms and routes of exposure

6. Legal exposure limit (if any)

7. Precautions for safe handling and use

8. Protective control measures

9. Personal protective equipment

10. Emergency and first aid measures

11. Spill and leak procedures

12. Contact information

13. Special Instructions

No specific order

Required

Under GHS SDS Sheets Require

1) Identification of the substance or mixture and of the supplier2) Hazard identification3) Composition/Information on ingredients4) First aid measures5) Fire-fighting measures6) Accidental release measures7) Handling and storage8) Exposure controls/personal protection9) Physical and chemical properties10)Stability and reactivity11)Toxicological information12)Ecological information13)Disposal information14)Transport information15)Regulatory information16)Other information

Sections must be in this Order!

Sections must be in this Order!

You must be trained on how to protect yourself from the hazardous chemicals you

work with.

• • Appropriate work practices

• • Personal protective equipment (PPE)

• • Emergency procedures

How does an employee protect themselves when working with a

hazardous chemical?

• What does the SDS say• Knowledge of Possible

Hazards• Personal Protective

Equipment• Location of Emergency

Equipment

Requirements of GHS

• Employees should already have been trained on the new elements they will see

• 6/1/2015 SDS should be received instead of MSDS. When reordering chemicals already in-house request SDS to replace MSDS (MSDS will suffice for

materials on hand)

CAUTION Watch SDS sheets for switched sections

Remember SDS hazard numbering system is inverse of NFPA