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 THREE

SAFETY DATA SHEETS (SDSs)

2Safety Data SheetsUnder the new Haz Com Standard, Material Safety Data Sheets (MSDS) are now called Safety Data Sheets (SDS).All SDSs will have a consistent 16-section format.Employers must ensure that SDSs are readily accessible to employees.

MaterialSafetyDataSheetsSafetyDataSheets

Manufacturers, importers and distributers may begin using the new 16-section format SDS (follows the ANSI standard) during the transition from the 1994 Haz Com standard and the final 2012 Haz Com standard but no later than June 1, 2015. They are required to provide a revised copy of the MSDS/SDS to the employer anytime changes are made.

Employers are required to maintain copies of all SDSs for the chemicals used and/or stored within the work area. They should have a system to ensure all SDSs are present/accounted and to periodically check for the most current SDS (usually based on revision date) when received from a manufacturer, importer or distributer.

The employer is to maintain a copy of the most current SDS and archive prior MSDSs/SDSs. SDSs are to accessible/available to employees.

As stated previously, if manufacturer is no longer in business, material safety data sheet for the product must kept as long as chemical is onsite/used then archived as required.3Safety Data Sheets (SDSs)New 16-section standardized SDS format required (ANSI Z400.1)Section 1 IdentificationSection 2 Hazard(s) identification Section 3 Composition / Information on IngredientsSection 4 First-aid MeasuresSection 5 Fire-fighting MeasuresSection 6 Accidental Release MeasuresSection 7 Handling and StorageSection 8 Exposure Controls / Personal ProtectionSection 9 Physical and Chemical PropertiesSection 10 Stability and ReactivitySection 11 Toxicological InformationSection 12 Ecological Information*Section 13 Disposal Consideration*Section 14 Transport Information*Section 15 Regulatory Information*Section 16 Other information including date of preparation of last revision*Sections outside of MIOSHA jurisdiction but inclusion of these sections is necessary for a GHS compliant SDS

4Manufacturers, importers and distributers may begin using the new 16-section format SDS during the transition from the 1994 Haz Com standard and the final 2012 Haz Com standard but no later than June 1, 2015. They are required to provide a revised copy of the MSDS/SDS to the employer anytime changes are made.

Employers are required to maintain copies of all SDSs for the chemicals used and/or stored within the work area. They should have a system to ensure all SDSs are present/accounted and to periodically check for the most current SDS (usually based on revision date) when received from a manufacturer, importer or distributer.

The employer is to maintain a copy of the most current SDS and archive prior MSDSs/SDSs. SDSs are to be accessible/available to employees.

Appendix D provides additional requirements for the information to be included under each section heading.

Section 1 requires restriction(s) on use.Section 2 requires: Classification Signal word, symbols, hazard and precautionary statements, Hazards not otherwise classified, Unknown toxicity statements when 1% or more of the components has unknown toxicity. X percent of the mixture consists of ingredients of unknown toxicity.Section 3 requires percentage.

MIOSHA will not enforce sections 12 15.Sections 12-15 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

Section 1 Identification:Identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier.

Section 2 - Hazards Identification:Hazards of the chemical presented on the SDS Appropriate warning information associated with those hazards.Safety Data Sheets (continued)

Section 1The required information consists of: Product identifier used on the label and any other common names or synonyms by which thesubstance is known. Name, address, phone number of the manufacturer, importer, or other responsible party, andemergency phone number. Recommended use of the chemical (e.g., a brief description of what it actually does, suchas flame retardant) and any restrictions on use (including recommendations given by thesupplier).

Section 2

The required information consists of: The hazard classification of the chemical (e.g., flammable liquid, category1). Signal word. Hazard statement(s). Pictograms (the pictograms or hazard symbols may be presented as graphical reproductionsof the symbols in black and white or be a description of the name of the symbol (e.g., skulland crossbones, flame). Precautionary statement(s). Description of any hazards not otherwise classified. For a mixture that contains an ingredient(s) with unknown toxicity, a statement describing howmuch (percentage) of the mixture consists of ingredient(s) with unknown acute toxicity. Pleasenote that this is a total percentage of the mixture and not tied to the individual ingredient(s).5Safety Data Sheets (continued)Section 3 Composition / Ingredients:Identifies the ingredient(s) contained in the product indicated on the SDS, including:impurities and stabilizing additives. information on substances, mixtures, and all chemicals where a trade secret is claimed.

Section 4 - First-Aid Measures:Describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical.

Section 3The required information consists of:Substances Chemical name. Common name and synonyms. Chemical Abstracts Service (CAS) number and other unique identifiers. Impurities and stabilizing additives, which are themselves classified and which contribute tothe classification of the chemical.Mixtures Same information required for substances. The chemical name and concentration (i.e., exact percentage) of all ingredients which areclassified as health hazards and are: Present above their cut-off/concentration limits or Present a health risk below the cut-off/concentration limits. The concentration (exact percentages) of each ingredient must be specified exceptconcentration ranges may be used in the following situations: A trade secret claim is made, There is batch-to-batch variation, or The SDS is used for a group of substantially similar mixtures.Chemicals where a trade secret is claimed A statement that the specific chemical identity and/or exact percentage (concentration) ofcomposition has been withheld as a trade secret is required.

Section 4The required information consists of: Necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact,and ingestion). Description of the most important symptoms or effects, and any symptoms that are acute ordelayed. Recommendations for immediate medical care and special treatment needed, when necessary.6Safety Data Sheets (continued)Section 5 Fire-Fighting Measures:Provides recommendations for fighting a fire caused by the chemical.

Section 6 - Accidental Release Measures:Provides recommendations:Appropriate response to spills, leaks, or releases, (e.g. containment and cleanup practices)Response for large vs. small spills, if different.

Section 5The required information consists of: Recommendations of suitable extinguishing equipment, and information about extinguishingequipment that is not appropriate for a particular situation. Advice on specific hazards that develop from the chemical during the fire, such as anyhazardous combustion products created when the chemical burns. Recommendations on special protective equipment or precautions for firefighters.

Section 6The required information may consist of recommendations for: Use of personal precautions (such as removal of ignition sources or providing sufficientventilation) and protective equipment to prevent the contamination of skin, eyes, and clothing. Emergency procedures, including instructions for evacuations, consulting experts whenneeded, and appropriate protective clothing. Methods and materials used for containment (e.g., covering the drains and cappingprocedures). Cleanup procedures (e.g., appropriate techniques for neutralization, decontamination, cleaningor vacuuming; adsorbent materials; and/or equipment required for containment/clean up).7Safety Data Sheets (continued)Section 7 Handling and Storage:Provides guidance on the safe handling practices and conditions for safe storage of chemicals.

Section 8 Exposure Controls / Personal Protection:Indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure.

Section 7The required information consists of: Precautions for safe handling, including recommendations for handling incompatiblechemicals, minimizing the release of the chemical into the environment, and providing adviceon general hygiene practices (e.g., eating, drinking, and smoking in work areas is prohibited). Recommendations on the conditions for safe storage, including any incompatibilities. Provideadvice on specific storage requirements.

Section 8The required information consists of: OSHA Permissible Exposure Limits (PELs), American Conference of Governmental IndustrialHygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limit used orrecommended by the chemical manufacturer, importer, or employer preparing the safety datasheet, where available. Appropriate engineering controls (e.g., use local exhaust ventilation, or use only in an enclosedsystem). Recommendations for personal protective measures to prevent illness or injury from exposureto chemicals, such as personal protective equipment (PPE) (e.g., appropriate types of eye, face,skin or respiratory protection needed based on hazards and potential exposure). Any special requirements for PPE, protective clothing or respirators (e.g., type of glove material,such as PVC or nitrile rubber gloves; and breakthrough time of the glove material).8Safety Data Sheets (continued)Section 9 Physical and Chemical Properties:Identifies physical and chemical properties associated with the substance or mixture.

Section 10 Stability and ReactivityDescribes the reactivity hazards of the chemical and the chemical stability information. Includes: reactivity, chemical stability, and other.

Section 9The minimum required information consists of: Appearance (physical state, color, etc.); Upper/lower flammability or explosive limits; Odor; Vapor pressure; Odor threshold; Vapor density; pH; Relative density; Melting point/freezing point; Solubility(ies); Initial boiling point and boiling range; Partition coefficient: n-octanol/water; Flash point; Auto-ignition temperature; Evaporation rate; Decomposition temperature; and Flammability (solid, gas); Viscosity.The SDS may not contain every item on the above list because information may not be relevant or is not available. When this occurs, a notation to that effect must be made for that chemical property. Manufacturers may also add other relevant properties, such as the dust deflagration index (Kst) for combustible dust, used to evaluate a dusts explosive potential.

Section 10The required information consists of:Reactivity Description of the specific test data for the chemical(s). This data can be for a class or family of the chemical if such data adequately represent the anticipated hazard of the chemical(s), where available.Chemical stability Indication of whether the chemical is stable or unstable under normal ambient temperature and conditions while in storage and being handled. Description of any stabilizers that may be needed to maintain chemical stability. Indication of any safety issues that may arise should the product change in physical appearance.Other Indication of the possibility of hazardous reactions, including a statement whether the chemical will react or polymerize, which could release excess pressure or heat, or create other hazardous conditions. Also, a description of the conditions under which hazardous reactions may occur. List of all conditions that should be avoided (e.g., static discharge, shock, vibrations, or environmental conditions that may lead to hazardous conditions). List of all classes of incompatible materials (e.g., classes of chemicals or specific substances) with which the chemical could react to produce a hazardous situation. List of any known or anticipated hazardous decomposition products that could be produced because of use, storage, or heating. (Hazardous combustion products should also be included in Section 5 (Fire-Fighting Measures) of the SDS.)9Safety Data Sheets (continued)Section 11 - Toxicological Information:Identifies toxicological and health effects information or indicates is data unavailable.Section 12 Ecological Information*Section 13 Disposal Consideration*Section 14 Transport Information*Section 15 Regulatory Information*

*Sections are outside of MIOSHA jurisdiction but must be included for a GHS compliant SDS.

Section 11The required information consists of: Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact).The SDS should indicate if the information is unknown. Description of the delayed, immediate, or chronic effects from short- and long-term exposure. The numerical measures of toxicity (e.g., acute toxicity estimates such as the LD50 (medianlethal dose)) - the estimated amount [of a substance] expected to kill 50% of test animals in asingle dose. Description of the symptoms. This description includes the symptoms associated withexposure to the chemical including symptoms from the lowest to the most severe exposure. Indication of whether the chemical is listed in the National Toxicology Program (NTP)Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in theInternational Agency for Research on Cancer (IARC) Monographs (latest editions) or foundto be a potential carcinogen by OSHA.

Sections 12-15 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.govSection 16, Other information, includes the date of preparation or last revision.

*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)).

See Appendix D of 1910.1200 for a detailed description of SDS contents.

10Safety Data Sheets (continued)Section 16 Other InformationIndicates when the SDS was prepared or when the last known revision was made.

The SDS may also state where the changes have been made to the previous version.

HMIS and NFPA secondary container labeling systems guidance might appear in this section of the SDS.11Revised Posters MSDS to SDS

MIOSHA Act 154 requires that posters noting the location and receipt of new or revised SDSs be placed in the work area.

Act 154 will be revised to be in compliance with GHS/Haz Com changes. This change may take some time to be effective.

This slide pictures the posters as they will appear with the anticipated change in wording from MSDS to SDS.12Have I completed the training?Maybe

13Has the following been provided by the employer?Employers must provide employees with the details of the facility specific hazard communication program:Location and availability of written program and SDSsSpecific information related to chemicals in the facility:Physical Hazards;Health Hazards;Hazards not otherwise classified.

Employers must provide facility specific instruction to employees as described on this slide and the next slide to be compliant with the Haz Com training requirements.

Employers must also maintain and periodically review the written Haz Com program for the facility which contains all of the information on this slide and the next slide.14Has the following been provided by the employer? (continued)Chemical list, location and use of hazardous chemicalsSecondary container labeling system Specific procedures to follow to protect employees from the chemical hazardMethods used to detect the presence or release of hazardous chemicals (sensor alarms, odors, visual other monitoring devices)

?

Employee training requirements have been met if the employer has provided the contents of this training program including the facility specific supplemental training.15Federal OSHA ResourcesHaz Com Web Page - www.osha.gov/dsg/hazcom/index.htmlRegulatoryHaz Com 2012 Final Rule

Haz Com Comparison: Haz Com 1994 and 2012 Side-by-side Redline Strikeout of the Regulatory Text

FAQsGuidance OSHA Briefs Fact Sheet Quick Cards LabelingSafety Data SheetsPictogramsEffective DatesOSHA Guide to GHSwww.osha.gov/dsg/hazcom/ghs.htmlGHS documents (links to purple book)

This slide highlights some of the additional resources available on the Federal OSHA website.

OSHA Haz Com Web Page: www.osha.gov/dsg/hazcom/index.htmlOSHA Guide to GHS: www.osha.gov/dsg/hazcom/ghs.html

16MIOSHA ResourcesGHS Webpage on MIOSHA Websitewww.michigan.gov/lara/0,4601,7-154-61256_11407-284831--,00.htmlEmployee Training PowerPoint CET library handouts:CET-5531 - GHS Overview of Major ChangesCET-5532 Lists other affected StandardsCET-5533 Signage ChangesCET DVDs/Video Lending library servicesState-wide Outreach seminarsGuidance documents & Revised posters

This slide highlights some of the additional resources available on the MIOSHA website.

State-wide Outreach seminars will be held. Additional details can be found on the MIOSHA CET training calendarhttp://www.michigan.gov/lara/0,4601,7-154-61256_11407_15317-40999--,00.html

The link to the CET DVD lending library ishttp://www.michigan.gov/lara/0,4601,7-154-61256_11407_30453-40855--,00.html

17Training SummaryTodays training program included:Overview of changes to the MIOSHA Part 42, 92 and 430: Hazard Communication Standard (Haz Com)Labeling requirementsSafety Data Sheets (SDS) format 16 categoriesDetails of the facility specific hazard communication programResources

18Questions Contact MIOSHA for information or assistance:

MIOSHA Consultation Education and Training7150 Harris Drive, P.O. Box 30643Lansing, Michigan 48909-8143(517) 322-1809www.michigan.gov/miosha

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