osha and ghs hazcom training by marie athey

© 2013 360training.com© 2013 360training.com

Marie Athey, OHST

GHS and Hazardous Communication Compliance

Are You Ready to Meet the 12/1/2013 Deadline?

© 2013 360training.com

Marie Athey, OHST

• Director of EHS Product Line Management at 360training.com• Degreed with over 15 years of EHS experience having worked

for various US companies in Construction and General Industry.• Training certifications:

– ANSI ASTM CAP– OHST designated by BCSP– OSHA 500 and 501 Instructor 10/30 hour classes – Competent Person Trainer- Trenching / Excavation– Competent Person Trainer – Fall Protection– Competent Person Trainer- Scaffold – HAZWOPER Instructor 1910.120– First Aid/CPR /AED Instructor- Medic First Aid– Approved Professional Source- State of Texas – Texas Department of

Insurance #1952


Objectives

• Understand the Scope of Globally Harmonized System (GHS) -15 Minutes– What is it?– Who is affected?

• Significant Changes - 30 Minutes– Phases of implementation– Training topics– Labels and SDS– Free resources available

• Are You in Compliance? -15 Minutes– Written Hazard Communication Program– Training solutions


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GHS

Ready to Comply?

HAZARDOUS COMMUNICATION STANDARD

RIGHT TO KNOW 29CFR 1910.1200


Some Interesting Facts about Hazard Communication Standard and Globally Harmonized System

• Over 50 Million American workers are exposed to hazardous chemicals in their workplaces.

• Over 5 Million Businesses will be impacted by the new GHS requirements for labeling and SDS.

• HCS covers some 650,000 hazardous chemical products found in over five million establishments.

• In 2012, OSHA issued 4,696 citations for Hazard Communication (29 CFR 1910.1200) violations (mainly due to lack of training, labeling fail, access to MSDSs and lacking correct MSDSs).


Globally Harmonized System- What is it?

• OSHA revised its Hazard Communication Standard (HCS) March 2012

• Aligns with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS)


Globally Harmonized System (GHS)

• Nations recognized chemical hazards must be classified and labeled under a universally understood communications system to avoid risks to human health and the environment.

• Nations throughout the world agreed to harmonize chemical hazard communications under a system developed by the United Nations (UN) and the International Labor Organization (ILO).

• Globally Harmonized System of Classification and Labeling of Chemicals (GHS), adopted by consensus in 2003 by the United Nations Economic and Social Council.


Phases of Implementation

By December 1, 2013, Employees must be trained on new labeling and SDSTo help companies

comply with the revised standard, OSHA is phasing in the specific requirements over several years (December 1, 2013 to June 1, 2016).


Two Significant Changes

Training Requirement:

New labeling elements

Training Requirement:

Standardized format for Safety Data Sheets (SDSs)

Improve worker understanding of the hazards


Label Elements

Training Requirement


OSHA Minimum Required Training Topics

Training tip from Dr. Michaels: Label Elements

1. Product Identifier

2. Signal Word

3. Pictogram

4. Hazard Statement

5. Precautionary Statements

6. Name, address, phone of manufacturer, distributor, importer

OSHA requires employers: (with all training)

Present information in a manner and language that their employees can understand.

If employers customarily need to communicate work instructions or other workplace information to employees in a language other than English, they will also need to provide safety and health training to employees in the same manner.

Similarly, if the employee’s vocabulary is limited, the training must account for that limitation.

By the same token, if employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation.


Required Training- Labels

Label Elements

1. Product Identifier

2. Signal Word

3. Pictogram

4. Hazard Statement

5. Precautionary Statements


Do you recognize the six elements?


Label Elements

1. Product Identifier• Chemical Name• Code number or batch number• Manufacturer, importer or distributor can decide the

appropriate product identifier • Product identifier must be both on the label and in

Section 1 of the SDS (Identification)


Label Elements

2. Signal Word– Used to indicate the relative level of severity of hazard

and alert the reader to a potential hazard on the label. – Two Words: “Danger” and “Warning.”– “Danger” is used for more severe hazards.– “Warning” is used for less severe hazards.– There will only be one signal word on the label no

matter how many hazards a chemical may have.– If one of the hazards warrants a “Danger” signal

word and another warrants the signal word “Warning,” then only “Danger” should appear on the label.


Label Elements

Examples:

3. Pictogram:(hazard pictograms) with red border

*A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label.


Pictograms


Label Element:

4. Hazard Statement

• Describe the nature of the hazard(s) of a chemical.

For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed

through the skin.” • All of the applicable hazard statements must appear on the label.• Hazard statements may be combined where appropriate to reduce

redundancies and improve readability.• Hazard statements are specific to the hazard classification

categories.• Chemical users should always see the same statement for the same

hazards, no matter what the chemical is or who produces it.


Label Elements

5. Precautionary Statement– 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.

Example: Labels give workers information on correct storage of the chemical or exposure effects.

Example: Information on the label might be used to quickly locate information on first aid when needed by employees or emergency personnel.



How the elements work together on a label

• Where a chemical has multiple hazards, different pictograms are used to identify the various hazards.

• Employees should expect to see the appropriate pictogram for the corresponding hazard class.

• When there are similar precautionary statements, the one providing the most protective information will be included on the label.


Safety Data Sheets (SDS)

Training Requirement


Safety Data Sheet (SDS)

• As of June 1, 2015, the HCS will require new SDSs to be in a uniform format, and include the section numbers, the headings, and associated information.


SDS Training Requirements

Training on the format of the SDS must include information on:

1. Standardized 16-section format, including the type of information found in the various sections

Example- the employee should be instructed that with the new format, Section 8 (Exposure Controls/Personal Protection) will always contain information about exposure limits, engineering controls and ways to protect yourself, including personal protective equipment.

2. How the information on the label is related to the SDS

Example- explain that the precautionary statements would be the same on the label and on the SDS.


New Safety Data Sheet (SDS) Format

• Section 1, Identification• Section 2, Hazard(s)

Identification• Section 3,

Composition/Information on Ingredients

• Section 4, First Aid Measures• Section 5, Fire Fighting

Measures• Section 6, Accidental Release

Measures• Section 7, Handling and Storage• Section 8, Exposure Controls/

Personal Protection

• Section 9, Physical and Chemical Properties

• Section 10. Stability and Reactivity

• Section 11, Toxicological Information

• Section 12, Ecological Information

• Section 13, Disposal Considerations

• Section 14. Transport Information• Section 15, Regulatory

Information• Section 16, Other Information



• Section 1, Identification– includes product

identifier, manufacturer or distributor name, address, phone number; emergency phone number, recommended use, restrictions on use.



• Section 2, Hazard(s) Identification– includes all hazards

regarding the chemical; required label elements.



• Section 3, Composition/ Information on Ingredients– includes information

on chemical ingredients; trade secret claims.



• Section 4, First aid Measures– includes important

symptoms/effects, acute, delayed; required treatment.



• Section 5, Fire Fighting Measures– lists suitable extinguishing techniques, equipment; chemical

hazards from fire.



• Section 6, Accidental Release Measures– lists emergency

procedures, protective equipment, proper methods of containment and cleanup.



• Section 7, Handling and Storage– lists precautions for

safe handling and storage, including incompatibilities.



• Section 8, Exposure Controls/ Personal Protection– lists OSHA’s

Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).



• Section 9, Physical and Chemical Properties– lists the chemical’s

characteristics.



• Section 10, Stability and Reactivity– lists chemical stability

and possibility of hazardous reactions.



• Section 11, Toxicological Information– includes routes of

exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.



• Section 12, Ecological information*• Section 13, Disposal considerations*• Section 14, Transport information*• Section 15, Regulatory information*

Note: Since other Agencies regulate this information,

OSHA will not be enforcing Sections 12 through 15

(29 CFR 1910.1200(g)(2)).



• Sections 12 and 13• Examples

SDS Vs. MSDS



• Section 14• Example:

SDS Vs. MSDS



• Section 15• Example:

SDS Vs. MSDS



• Section 16, Other Information– includes the date of

preparation or last revision.


Free Supplemental Resources

• OSHA Fact Sheet – Training Requirements for the Revised Hazard Communication Standard– https://www.osha.gov/Publications/OSHA3642.pdf

• Quick Card SDS– https://www.osha.gov/Publications/OSHA3493QuickCardSafety

DataSheet.pdf

• Quick Card Labels– https://www.osha.gov/Publications/HazComm_QuickCard_Label

s.html

https://www.osha.gov/Publications/OSHA3642.pdf

https://www.osha.gov/Publications/OSHA3493QuickCardSafetyDataSheet.pdf

https://www.osha.gov/Publications/OSHA3493QuickCardSafetyDataSheet.pdf

https://www.osha.gov/Publications/HazComm_QuickCard_Labels.html

https://www.osha.gov/Publications/HazComm_QuickCard_Labels.html


Hazardous Communication

Compliance


Checklist to Comply with HCS

Obtain a copy of the rule. (29CFR1910.1200) osha.gov Read and understand the requirements. Assign responsibility for tasks. Prepare an inventory of chemicals. Ensure containers are labeled. Obtain SDS for each chemical. Prepare Hazardous Communication written program. Make SDSs available to workers. Conduct training for workers upon hire, annually, change. Establish procedures to maintain current program. Establish procedures to evaluate effectiveness.


We Have a Course for That

• GHS and OSHA Hazardous Communication demo


Need additional Guidance?

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