Hazard Communication Employee Training Program

Hazard Communication Training Program(including GHS revisions)Prepared by Consultation Education & Training (CET) DivisionMichigan Occupational Safety & Health Administration Michigan Department of Licensing and Regulatory Affairs www.michigan.gov/miosha(517) 322-1809

(Revised: 08/23/13)

Last revised: 08/23/13 Jenelles updates

This training session is designed to provide information to employees who work with hazardous chemicals and substances. Employers are required to provide training to employees by December 1, 2013.

08/16/13: Minor revisions were made associated with the compliance dates listed in the speakers notes on a few slides.1AgendaOverview of changes to the MIOSHA Part 42, 92 and 430: Hazard Communication Standard (Haz Com)Labeling requirementsSafety Data Sheets (SDS) format 16 sectionsSupplemental Employee Training (to be provided by employer)

This training includes:An overview of the changes to the MIOSHA Haz Com Standard;The new labeling requirements;Information on the new safety data sheets in the 16 section format; and,Details of the facility specific haz com program. This portion of the training program is designed to provide guidance to employers on information they must include in order for the employee training program to be compliant with the MIOSHA Haz Com Standard. 2MODULE ONE

Overview and Classification

3Why the Change to Haz Com?To align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) adopted by 67 nationsTo provide a common and coherent approach to classifying chemicalsReduce confusion and increase understanding of the hazardsFacilitate trainingHelp address literacy problems

4So, why the change?Since 1992, the United Nations have been working to create and enhance a globally harmonized system for the classification and labeling of chemicals that can be used by importers, distributers and manufacturers worldwide.

2012 Haz Com revised standard is based on GHS revision 3.

The goal is to provide a common and coherent approach to classifying chemicals.

This will benefit employees as it will:Reduce confusion and increase understanding of the hazards.Facilitate trainingHelp address literacy problems particularly due to use of pictogramsWho is Affected?Manufacturers, Distributors, ImportersChange SDS information and formatChange container labelingEmployersTraining employees on changes to:SDS (change from MSDS to SDS and 16-section format)Container Labels (including secondary containers)EmployeesRecognize and understand hazards based on:Information in new SDS formatPictograms on container labelsPrecautionary and hazard statements

5Other Standards Affected Health(signage requirements)AsbestosCarcinogensVinyl ChlorideInorganic ArsenicLeadCadmiumBenzene

Coke Oven EmissionsAcrylonitrileEthylene OxideFormaldehydeMethylenedianilineDANGERLEADMAY DAMAGE FERTILITYOR THE UNBORN CHILDCAUSES DAMAGE TO THECENTRAL NERVOUSSYSTEMDO NOT EAT, DRINK OR SMOKE IN THIS AREAWARNINGLEAD WORK AREAPOISONNO SMOKING OR EATINGNew SignLEAD

This slide lists the other MIOSHA standards that are affected by the changes adopted in the 2012 Haz Com. Language on required signs in the listed standards, will be harmonized with Haz Com and GHS.

For example the sign for lead will be changed as noted above.Chromium (VI) does not appear to have any changes. Refer to the signage handout (CET-5533) or the GHS page on the MIOSHA website, for additional information on signage requirements.http://www.michigan.gov/documents/lara/lara_miosha_cet5533_402987_7.docx

Note: Label requirements for substance specific standards must be completed on or by June 1, 2015.

Example: Asbestos pipe wrap (thermal system insulation) label must have be new language and placed by June 1, 2015, but the sign for the regulated area (area under abatement) must be updated by June 1, 2016. 6Flammable and Combustible LiquidsSpray Finishing using Flammable and Combustible MaterialsProcess Safety Management of Highly Hazardous Chemicals (PSM)Hazardous Waste Operations and Emergency Response (HAZWOPER)Hazardous Work In LaboratoriesDipping and Coating OperationsWelding, Cutting and BrazingEmployee Medical Records and Trade SecretsOther Standards Affected

Here is a list of the other standards affected.

In some cases, definitions may have changed in the standards listed above.

Chromium (VI) does not appear to have any changes.

Refer to the handout CET-5532 or the GHS page on the MIOSHA website, for additional information on the other Standards affected:http://www.michigan.gov/documents/lara/lara_miosha_cet5532_402986_7.doc

7Effective Dates and RequirementsEffective Completion DateRequirement(s)Responsible PartyDecember 1, 2013Train employees on the new label elements and SDS formatEmployersJune 1, 2015Compliance with all modified provisions of the final rule except:Chemical manufacturers, importers, distributors, and employersDecember 1, 2015The distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS labelDistributorJune 1, 2016Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified hazards [and affected vertical standard specific signage] EmployerTransition Period: 12/2012 to the effective completion dates noted aboveMay comply with either MIOSHA Part 42, 92 and 430 (final standard), or the current standard, or bothChemical manufacturers, importers, distributors, and employers

This chart was provided by Federal OSHA with one addition which is noted in brackets.

Effective on or by June 1, 2015:- All SDS must be completed and shipped/sent to users with the 1st order shipped on or after June 1, 2015.Employers/users of chemicals review to ensure all SDS received on or after June 1, 2015 are in the new format. Per OSHA, employers are not required to pursue getting new SDSs for products received before June 1, 2015; unless they are aware of changes to the hazards in the product. For older products, material safety data sheets for the products must kept as long as chemical is onsite/use,d then archived as required.- Vertical chemical specific standards with label requirements must be changed to harmonize with 1910.1200 Haz Com.

Effective on or by June 1, 2016 - Employer/user must have program updated including any additional training and any label changes completed.- Vertical chemical specific standards with signage requirements will be changing to harmonize with 1910.1200 Haz Com. The added text in brackets reflects this.

8Chemical ClassificationsChemicals will be classified using a harmonized system that provides standardized language for:

Health Hazard CategoriesPhysical Hazard CategoriesEnvironmental Hazard Categories**Not regulated by MIOSHA.

Previously, chemical hazards were evaluated in a more subjective manner.

Chemicals must now go through a specific, prescriptive classification process to determine which hazards are present and which hazard and precautionary statements apply. This can be a lengthy process.

Environmental Hazards are not regulated by MIOSHA. Check with the Michigan Department of Environmental Quality (DEQ) for any employee training requirements for these sections. DEQ Environmental Assistance Center can be reached at (800) 662-9278 from 8 a.m. to 4:30 p.m., Monday through Friday or email: deq-assist@michigan.gov

9Chemical Classifications: Health HazardsAcute ToxicitySkin Corrosion/IrritationRespiratory or Skin SensitizationGerm Cell MutagenicityCarcinogenicityReproductive ToxicitySpecific Target Organ Toxicity Single ExposureSpecific Target Organ Toxicity Repeated ExposureAspirationSimple Asphyxiants

Now there are 10 established chemical health classifications; that are further defined and described in Appendix A of the Haz Com Standard.

Appendix A is to be used by manufacturers, importers and distributers to determine if any of their products are classified as a health hazards. If the product is classified as a health hazard in one or more of the 10 health hazard classifications listed on this slide, Appendix A is used to determine the severity of the hazard (or hazard category) under the applicable hazard class. More information noted in the chart on the next slide.

Note: Simple Asphyxiants are not part of the current GHS (international standard) but were specifically included by OSHA as a hazard classification under the 2012 Haz Com Standard. 10Chemical Classifications:Health HazardsHazard ClassHazard CategoryAcute toxicity1234Skin Corrosion/Irritation1A1B1C2Serious Eye Damage/Eye Irritation12A2BRespiratory or Skin Sensitization1Germ Cell Mutagenicity1A1B2Carcinogenicity1A1B2Reproductive Toxicity1A1B2LactationSpecific Target Organ Toxicity Single Exposure123Specific Target Organ Toxicity Repeated Exposure12Aspiration1Simple AsphyxiantsSingle Category

This chart shows the new health hazard classes and the hazard categories that correspond to each of the health hazard classes. Hazard category 1 (or column furthest to the left) is the most hazardous. Hazard categories become less severe as you move to the right in the chart.

Manufacturers, importers and distributers must classify all hazards for their products.

11Chemical Classifications: Physical HazardsExplosivesFlammable AerosolsOxidizing GasesGases under PressureCompressed GasesLiquefied GasesRefrigerated Liquefied GasesDissolves Gases

Each of the chemical physical classifications are further defined and described in Appendix B of the Haz Com Standard.

Appendix B is to be used by manufacturers, importers and distributers to determine if any of their products are classified as a physical hazard. If the product is classified as a physical hazard in one or more of the physical hazard classifications, Appendix B is used to determine the severity of the hazard (or hazard category). 12Chemical Classifications: Physical Hazards (continued)Flammable LiquidsFlammable SolidsSelf-Reactive ChemicalsPyrophoric LiquidsPyrophoric SolidPyrophoric GasesSelf-heating ChemicalsChemicals, which in contact with water, emit flammable gases

13Oxidizing LiquidsOxidizing SolidOrganic PeroxidesCorrosive to MetalsCombustible DustsChemical Classifications: Physical Hazards(continued)

Note: Pyrophoric Gases and Combustible Dust are not part of the GHS (international standard) but were specifically included by OSHA as physical hazard classifications under the 2012 Haz Com Standard. 14Chemical Classifications:Physical HazardsHazard ClassHazard CategoryExplosivesUnstable ExplosivesDiv 1.1Div 1.2Div 1.3Div 1.4Div 1.5Div 1.6Flammable Gases12Flammable Aerosols12Oxidizing Gases1Gases under Pressure Compressed gases Liquefied gases Refrigerated liquefied gases Dissolved gases1Flammable Liquids1234Flammable Solids12Self-Reactive ChemicalsType AType BType CType DType EType FType GPyrophoric Liquids1Pyrophoric Solids1Pyrophoric GasesSingle CategorySelf-Heating Chemicals12Chemicals in which contact with water emit flammable gases123Oxidizing Liquids123Oxidizing Solids123Organic PeroxidesType AType BType CType DType EType FType GCorrosive to Metals1Combustible DustSingle Category

This chart shows the physical hazard classes and the hazard categories that correspond to each of the physical hazard classes. Hazard category 1 (or column furthest to the left) is the most hazardous. Hazard categories become less severe as you move to the right in the chart.

Manufacturers, importers and distributers must classify all hazards for their products.15This Concludes Module One