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.1MODULE TWO

LABELS

2LabelsThere are several new label elements:Symbols called PictogramsSignal WordsHazard StatementsPrecautionary StatementsProduct IdentificationSupplier/Manufacturer Identification

www.osha.gov/Publications/HazComm_QuickCard_Labels.html

This is an example of the new label style that is to appear on product labels beginning no later than June 1, 2015 (or Dec. 1, 2015 for distributers who still have product in inventory after the June 1, 2015 deadline).

The type of required information is noted in blue. The actual statements and information will vary depending on the specific health and physical classification of the product.3Labels: ShippingEffective June 1, 2015 all shipping labels will be required to have all GHS label elements

DOT Shipping

Flammable liquids, toxic, n.o.s.(contains XYZ)UN 1992Shipping Container Label (55 gallon/200 liter drum)Pictograms within DOT label

Note the difference in the shipping label compared to the container label on the previous slide. Department of Transportation (DOT) requires that additional information be noted on shipping containers. See bottom right corner of the label for shipping.

MIOSHA requires that employees are knowledgeable of both the container and shipping labels.4Transport "Pictograms"Flammable Liquid Flammable Gas Flammable AerosolFlammable solid Self-Reactive SubstancesPyrophorics (Spontaneously Combustible) Self-Heating SubstancesSubstances, which in contact with water, emit flammable gases (Dangerous When Wet)Oxidizing Gases Oxidizing Liquids Oxidizing Solids Explosive Divisions 1.1, 1.2, 1.3Explosive Division 1.4Explosive Division 1.5 Explosive Division 1.6Compressed GasesAcute Toxicity (Poison): Oral, Dermal, Inhalation CorrosiveMarine Pollutant Organic Peroxides

Source: GHS Guide on OSHA website: http://www.osha.gov/dsg/hazcom/ghs.html#3.1Figure 4.10

These are DOT labels and may appear on transport containers depending on the classification of the chemical. Employers are required to train employees on shipping container labels they may encounter on the job.5

DOT and MIOSHA LabelsDOT labels may take precedence over similar GHS pictograms for shipping containers.DOT does not have labels that correspond to the Health Hazard or the Acute Toxicity (less severe = exclamation mark).

DOT does not view the GHS pictograms as a conflict and it is permissible to have the DOT and GHS pictogram for representing the same hazard. OSHA will not be enforcing the shall not appear requirement in Appendix C (C.2.3.3. states where a pictogram required by DOT under Title 49 of the CFR (code of federal regulations) appears on a shipped container, the pictogram specified in C.4 for the same hazard, shall not appear.6Labels: PictogramsThere are 9 pictograms. Only 8 are regulated by MIOSHAHealth Hazards Physical HazardsEnvironmental Hazards (Regulated by DEQ)

DEQ

There are 3 pictograms specific to health hazards: exclamation, health hazard (silhouette of a person with starburst on the chest) and skull and crossbones.

There is 1 pictogram that can represents both physical and/or health hazard of corrosive.

There are 4 pictograms specific to physical hazards: exploding bomb, flame, flame over circle (oxidizer) and gas cylinder.

There is 1 for environment: 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.gov7Labels: Pictograms Health Hazards

Acute toxicity (Less Severe):IrritantDermal sensitizerAcute toxicity (harmful)Narcotic effectsRespiratory tract irritationAcute toxicity (Severe)Acute = short-term effect

The following slides will provide more detail related to the pictograms.

These 2 pictograms are specific to acute toxicity (short-term exposure). The skull and crossbones is for any substance that is classified as having acute toxicity in health hazard category 1-3. The acute toxicity health class, category 4 (least hazardous) is represented by an exclamation mark.

If the substance is properly labeled, these 2 pictograms will never appear on the same label. It will be one or the other with skull and crossbones representing the more severe hazard.

Additional information for labeling and language associated with these pictograms is found in Appendix C of the Haz Com Standard.8Labels: Pictograms Health Hazards (continued)

Skin corrosionSerious eye damage/Eye irritation

CarcinogenRespiratory sensitizerReproductive toxicityTarget organ toxicityMutagenicityAspiration Hazard

Most employees should be familiar with the pictogram for corrosion on the left.

The pictogram to the right is called the health hazard pictogram and is represented by the silhouette of a person with a starburst across the chest. This is used indicate that the substance is a chronic and/or target organ hazard.9Labels: Pictograms Physical Hazards

FlammablesSelf reactivesPyrophoricsSelf heatingEmits flammable gasOrganic peroxides

ExplosivesSelf reactivesOrganic peroxides

The next 2 slides (4 pictograms) represent physical hazards.10Labels: Pictograms Physical Hazards(continued)

Corrosive to MetalsGases under PressureOxidizer

Note that the corrosive pictogram used to designate corrosion to metal is the same pictogram used for skin corrosion/serious eye damage/eye irritation under the health hazard classification.

Not all health hazards represented by this pictogram are corrosive to metal so it is important to look for additional information on the label and in the SDS.

Oxidizers are chemicals that can emit oxygen and increase the risk of fire.11Labels: Signal WordThese are words used to indicate the severity of the hazard and alert employees to the potential hazard.

Only 2 signal words will appear:DANGER(more severe hazard)WARNING (less severe hazard)

Not all labels will have a signal word. Some chemicals are not hazardous enough to require that a signal word appear on the label.

In the past, there have been several signal words that may have been used to indicate a hazard like caution, warning, danger.

The GHS permits the use of only 2 signal words: Danger and Warning. Only 1 of the signal words is permitted to appear on the label based on the classification of the chemical.12Labels: Hazard StatementThere are specific hazard statements that must appear on the label based on the chemical hazard classification.

Examples:Flammable liquid and vaporCauses skin irritationMay cause cancer

Definition of Hazard Statement:"Hazard statement" means 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.

Manufacturers, importers and distributers use the classification system outlined in GHS to identify which statements must appear in the SDS and on the label found in Appendix C.13Labels and other forms of warning Precautionary StatementsRecommended measures related to:PreventionResponseStorageDisposalExamples:Wear respiratory protectionWash with soap and waterStore in a well ventilated placeNot a mandate for employers/employees to follow.

"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. Precautionary statements can be found in Appendix C. 14Label: IdentificationProduct identification (i.e. name of product)Supplier identification:Address Telephone number

Definition of product identifier:"Product identifier" means the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS.15Label: Other informationOther information that may be included on the label:Physical stateColorHazards not otherwise classifiedRoute of exposureStorage and disposalHazard prevention and emergency response instructions

This is discretionary information that may be provided by the manufacturer, importer or distributer. This information is not required to be on the label; however it will be found in the SDS.16ToxiFlam (Contains: XYZ)

Danger! Toxic If Swallowed, Flammable Liquid and Vapor

Do not eat, drink or use tobacco when using this product. Wash hands thoroughly after handling. Keep container tightly closed. Keep away from heat/sparks/open flame. - No smoking. Wear protective gloves and eye/face protection. Ground container and receiving equipment. Use explosion-proof electrical equipment. Take precautionary measures against static discharge. Use only non-sparking tools. Store in cool/well-ventilated place.IF SWALLOWED: Immediately call a POISON CONTROL CENTER or doctor/physician. Rinse mouth.

In case of fire, use water fog, dry chemical, CO2, or "alcohol" foam.

See Safety Data Sheet for further details regarding safe use of this product.

MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 966 6666

Label: SampleCan you identify each label component?Signal Word

Hazard Statements

PrecautionaryStatementsProduct IdentifierSupplier IdentificationSupplemental InformationPictograms(Flammable and Acute Toxicity Severe)

Slide is animated to identify each required section/element of the new label.17Secondary Container LabelsExcerpt from the Hazard Communication Standard (f): (6) Workplace labeling. Except as provided in paragraphs (7) and (8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either: (i) The information specified under paragraphs (1)(i) through (v) of this section for labels on shipped containers [GHS Label]; or, (ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical [e.g. HMIS, NFPA or other label system].

Product Identifier = name or number unique to the chemical listed on the manufacturer label or in SDS.

Note: waste container labeling requirements are covered under EPA/DEQ rules. Contact DEQ for additional information.18Labels: Secondary containersMust be consistent with the revised Haz Com standardNo conflicting hazard warnings or pictograms. May use written materials (e.g., signs, placards, etc.) in lieu of affixing labels to individual stationary process containers.Employer can use GHS compliant labels (same as shipping).

NFPA LabelHEALTHFIREPHYSICAL HZPPEHMIS LabelMust include notation of chronic health effects

HMIS = Hazardous Materials Information System (American Coatings Association)NFPA = National Fire Protection Association

HMIS labeling system incorporates an * to inform employees of the presence of a chronic/target organ health effect. NFPA labeling system does not incorporate chronic effects and this must be included on NFPA labeled secondary containers if noted on the original manufacturer container. The health hazard pictogram (silhouette of a person with starburst on chest).

GHS vs. HMIS / NFPA 704NFPA & HMIS systems number 4 indicates a severe hazard. Under GHS Haz Com standard, when a manufacturer, importer, distributer classifies a chemical, a category 4 is the least severe and category 1 in the most severe.

GHS hazard category numbers may be noted in SDS; NOT required to be present on the container label.

ACA made modifications to HMIS ratings in 2001. Reactivity was changed to Physical Hazard and defined ranges modified. System is still 0 = least hazard and 4=greatest hazard) More information available at www.paint.org/programs/hmis.html

19This Concludes Module Two