OSHAHAZARD

COMMUNICATION UPDATE Kim G. Auletta

Stony Brook UniversityJune 2012

Have you started using any GHS elements in your Hazard Communication training?

A •Yes

B •No

C •Don’t know what GHS is

Topics

Major Changes

Why Update

Changes in Definition

Hazard Classification

Written Program

List of Chemicals Labels Safety Data

Sheets

Training To Do ListOther

Affected OSHA Standards

Effective Dates

Resources

Major Changes

Hazard ClassificationLabels

Safety Data Sheets

Information and Training

All Laboratories

Facilities

Visual Arts

Theater

Museum

Health Care

Who is Affected

Why Did OSHA Update HazCom?

To improve the safety and health of workers through more effective communications on

chemical hazards

Right to Know

Right to Understand

Benefits to UpdatePerformance Oriented Led to

Confusion

Standardized Approach

Improved Comprehension of the Standard

Safety Data Sheets Standardized

Changes to DefinitionsDelete• Combustible Liquid• Compressed Gas• Explosive• Flammable• Flashpoint• Hazard Warning• Identity• Material Safety Data Sheet• Organic Peroxide• Oxidizer• Pyrophoric• Unstable (reactive)• Water Reactive

Added• Classification• Hazard Category• Hazard Class• Hazard not otherwise classified• Label Elements• Pictogram• Precautionary Statement• Product Identifier• Pyrophoric Gas• Safety Data Sheet• Signal Word• Simple Asphyxiant• Substance

Revised Definitions

Chemical Chemical Name

Hazardous Chemical

Health Hazard Label Mixture

Physical Hazard

Trade Secret

ChemicalOLD

Any substance or

mixture of substances

NEW

Any element, chemical

compound or mixture of

elements and/or compounds

Chemical NameOLD

The scientific designation of a chemical in

accordance with the nomenclature system

developed by the International Union of Pure

and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS)

rules of nomenclature, or a name which will clearly identify the chemical for

the purpose of conducting a hazard evaluation.

NEWThe scientific designation

of a chemical in accordance with the

nomenclature system developed by the

International Union of Pure and Applied Chemistry

(IUPAC) or the Chemical Abstracts Service (CAS)

rules of nomenclature, or a name that will clearly

identify the chemical for the purpose of conducting

a hazard classification

Hazardous Chemical OLD

Any chemical which is a

physical hazard or a health

hazard

NEW

Any chemical which is classified as a physical

hazard or a health hazard, a simple

asphyxiant, combustible dust, pyrophoric gas, or

hazard not otherwise classified

Health HazardOLDA chemical for which there is

statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees.

The term "health hazard" includes chemicals which are:

• carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.

Appendix A provides further definitions and explanations of the scope of health hazards covered by this section.

Appendix B describes the criteria to be used to determine whether or not a chemical is to be considered hazardous for purposes of this standard.

NEWA chemical which is classified as posing one of the following hazardous effects:

• acute toxicity (any route of exposure);• skin corrosion or irritation;• serious eye damage or eye irritation;• respiratory or skin sensitization; • germ cell mutagenicity;• carcinogenicity; • reproductive toxicity; • specific target organ toxicity (single or repeated exposure);

or aspiration hazard. The criteria for determining whether a chemical is classified as a health hazard are detailed in Appendix A to §1910.1200 -- Health Hazard Criteria

LabelOLD

Any written, printed, or graphic material

displayed on or affixed to containers

of hazardous chemicals

NEWAn appropriate group of

written, printed or graphic information elements

concerning a hazardous chemical that is affixed to, printed on, or attached to

the immediate container of a hazardous chemical, or to

the outside packaging.

MixtureOLD

Any combination of two or more

chemicals if the combination is not, in whole or in part,

the result of a chemical reaction

NEW

A combination or a solution

composed of two or more

substances in which they do not

react

Physical HazardOLD

A chemical for which there is scientifically valid evidence that it is a

combustible liquid, a compressed gas, explosive,

flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-

reactive.

NEWA chemical that is classified as

posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-

reactive; pyrophoric (liquid or solid); self-heating; organic

peroxide; corrosive to metal; gas under pressure; or in contact

with water emits flammable gas. See Appendix B to §1910.1200 --

Physical Hazard Criteria.

Trade SecretOLD

Any confidential formula, pattern, process, device,

information or compilation of information that is used in an employer's business, and that

gives the employer an opportunity to obtain an

advantage over competitors who do not know or use it. Appendix D sets out the criteria to be used

in evaluating trade secrets.

NEWAny confidential formula, pattern,

process, device, information or compilation of information that is used in an employer's business, and that gives the employer an

opportunity to obtain an advantage over competitors who do not know or use it. Appendix E to §1910.1200–Definition of Trade Secret, sets out the criteria to be used in evaluating trade secrets.

Specific Criteria

2012 Approach Different from 1994

AppendicesA & B

No Additional Testing

Hazard Classificatio

n

Hazard Classificatio

n

Hazard Class

Hazard Category

Evaluation

Category 1

Category 2

Manufacturer’s Responsibility!

Example: Acute Toxicity

Mixtures

Include all hazardous chemicals

>1% or carcinogens

>0.1%

% changes depends

on hazard class and category

OLD NEW

Safety Data Sheets

New Labeling Format

No “Substantive” Changes

Possible Changes to Chemical List

Written Program

List of ChemicalsIdentityProduct Identifier

Do you think the new Hazard Communication requirements will:

A •Provide the workers with a better understanding of the chemical hazards they may be exposed to

B •Create more work for our overburdened EH&S staff

C •Don't expect any changes in our program

LabelsProvides detailed and specific labeling requirements. No longer performance oriented approach.

Once a chemical is classified, specific label elements and information for each hazard class and category are required.

Requires pictograms, signal word, and hazard & precautionary statements on labels.

Label Elements

Manufacturer’s

Responsibility

Product Identifier

Signal Word

Pictogram

Supplier & Manufacturer

Name, Address & Phone

Hazard Statement including

Hazard Class and Category

PrecautionaryStatements

Specified pictogram, hazard statement, signal word and precautionary

statement for each hazard class and category.

Appendix C provides required elements for each hazard class and categoryhttp://www.osha.gov/FedReg_osha_pdf/FED20120326.pdf page 251

Pictograms

Explosives Self Reactives

Organic Peroxides

Oxidizers

Flammables Pyrophorics Self-Heating

Emits Flammable Gas

Acute Toxicity (severe)

Corrosives Gases under pressure

CarcinogenMutagenicity

Reproductive Toxicity Respiratory SensitizerTarget Organ Toxicity

Aspiration Toxicity

Aquatic Toxicity

Irritant Skin Sensitizer

Acute Toxicity (Harmful)Narcotic Effects

Respiratory Tract Irritation Hazardous to Ozone Layer

http://www.osha.gov/Publications/OSHA3492QuickCardLabel.pdf

In House LabelsAlternatives are permitted for in house labeling BUT the information must be

consistent with the new format and label elements.

Original label or

Product identifier and words, pictures,

symbols or combination to provide general information on the

hazards

Hazard classification system must be

consistent with updated GHS

Safety Data SheetsSpecific sections and the order they are to be listed on the Safety Data Sheets are now required.

16 section format similar to the ANSI standard for‑ Hazardous Workplace Chemicals-Hazard Evaluation and Safety Data Sheets and Precautionary Labeling Preparation (ANSI Z400.1 & Z129.1 - 2010).

Uniformity will improve the effectiveness of the safety data sheet.

Safety Data Sheet1

• Identification• Identifies the chemical, recommended uses and

the essential contact information of the supplier.

2• Hazards Identification

• Identifies the hazards of the chemical and the appropriate warning information associated with those hazards.

3• Composition/Information on Ingredients

• Identifies the ingredient(s) in the product, including impurities and stabilizing additives and any trade secret claims.

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.

Safety Data Sheet

5• Fire Fighting Measures

• Recommendations for fighting a fire caused by the chemical.

6 • Accidental Release Measures• Recommendations on the appropriate

response to spills, leaks, or releases.

7 • Handling and Storage• Guidance on the safe handling practices and

conditions for safe storage.

8 • Exposure Controls & Personal Protection• Exposure limits, engineering controls, and

personal protective measures.

Safety Data Sheet

9 •Physical and Chemical Properties

10 •Stability and Reactivity

11 •Toxicological Information

12 •Ecological Information

Safety Data Sheet

13• Disposal

Considerations

14 • Transport Information

15 • Regulatory Information

16• Other information

including date of preparation or last revision

GHS SDS Elements

Signal words: “Danger” or “Warning”

72 individual and 17 combined Hazard Statements

116 individual and 33 combined Precautionary Statements

Statement Summary

http://www.sigmaaldrich.com/safety-center/globally-harmonized.html

Methanol SDS from Sigma

Completed by December 1, 2013

Not required to address the specific hazards of the chemicals or the protective measures

All training provisions remain the same as the HCS 1994

OSHA provides no new guidance on HOW to provide training on new SDS & labels

GHSTraining

To Do

Train all employees in new SDS format

• Include:• The order of information on the SDS• How employees can obtain SDS• How to obtain and use the appropriate hazard

information• http://www.osha.gov/dsg/hazcom/osha-brief.html

To Do

Train all employees in new label format

• Include:• Product Identifier• Signal words (Danger & Warning)• Pictograms• Hazard Statements• Precautionary Statements

• http://www.osha.gov/Publications/HazComm_QuickCard_Labels.html

Chemical Game

Chemical Game

Quiz1. Which PICTOGRAM is on the Clorox Bleach container?

a. Health Hazardb. Exploding Bombc. Corrosiond. Skull & Crossbones

2. Which Section # on the SDS will you find what kind of gloves you need to wear?a. Section 1b. Section 5c. Section 8d. Section 11

3. Which product will have a HEALTH HAZARD Pictogram?a. Asbestosb. Acetic Acidc. Ammoniad. Anise

4. Which SIGNAL WORD is the greater hazard?a. Dangerb. Warning

5. Which section of the LABEL will tell you how to handle the product safely?a. Identifierb. Pictogramc. Hazard Statementd. Precautionary Statement

Given to staff after providing copies and reviewing the OSHA

Quick Cards for Pictograms, Labels and SDS

To Do

Train employees in new hazard classes that may not have been covered in previous program.

• Simple asphyxiant• Pyrophoric gas• Combustible dust• Hazard not otherwise classified• Update Haz Com Training for all new employees

No later than June 1, 2016

Other OSHA Standards

1910.106 Flammable Liquids

• Not more than 60 gallons of Category 1, 2, or 3 flammable liquids, nor more than 120 gallons of Category 4 flammable liquids may be stored in a storage cabinet.Container Cat 1 Cat 2 Cat 3 Cat 4

Glass or approved plastic 1 pt 1 qt 1 gal 1 gal

Metal 1 gal 5 gal 5 gal 5 gal

Safety Cans 2 gal 5 gal 5 gal 5 gal

Definition Changes1910.107 Spray finishing using flammable and combustible materials

1910.119 Process safety management of highly hazardous chemicals

1910.120 Hazardous waste operations and emergency response

1910.123 Dipping and coating operations

1910.252 Welding, Cutting and Brazing

1910.1450 Occupational exposure to hazardous chemicals in laboratories

Changes to definitions only to align terms with GHS

• Removed combustible liquid, compressed gas, explosive, flammable, flashpoint, organic peroxide, oxidizer, unstable (reactive), water-reactive• Revised hazardous chemical, physical hazard, reproductive toxins• Added health hazard, mutagen• Changed “material safety data sheet” to “safety data sheet”

No changes to any requirements, including labeling

Definitions, Signs and Labels

1910.1001 Asbestos

• Specific chemical standards

1910.1003 “13 Carcinogens”

1910. 10xx

1910.1048 Formaldehyde

Signs for Regulated Area

• DANGER FORMALDEHYDE• MAY CAUSE CANCER• CAUSES SKIN, EYE, AND RESPIRATORY IRRITATION• AUTHORIZED PERSONNEL ONLY

Labels for containers of contaminated clothing & equipment

• DANGER FORMALDEHYDE-CONTAMINATED [CLOTHING] EQUIPMENT• MAY CAUSE CANCER• CAUSES SKIN, EYE, AND RESPIRATORY IRRITATION• DO NOT BREATHE VAPOR DO NOT GET ON SKIN

Communication

• Classify the hazards of formaldehyde to include: Cancer; skin and respiratory sensitization; eye, skin and respiratory tract irritation; acute toxicity effects; and flammability• Material capable of releasing formaldehyde at levels above 0.5 ppm: labels shall address all hazards, including cancer and respiratory sensitization, and shall contain the hazard statement

"May Cause Cancer."• Materials capable of releasing formaldehyde at levels of 0.1 ppm to 0.5 ppm: labels shall identify that the product contains formaldehyde; list the name and address of the responsible party;

and state that physical and health hazard information is readily available from the employer and from safety data sheets.

Effective Dates

Employers must train employees on the new label elements and safety data sheet format by December 1, 2013

• distributors to ensure all manufacturer labels are updated. • all employers must ensure that updated workplace signs, hazard communication program,

and training necessary for newly identified physical or health hazards are in place.

All other provisions are to be in effect by June 1, 2016

ResourcesOSHA

• http://www.osha.gov/dsg/hazcom/index.html

NIOSH/ICSC Cards

• http://www.cdc.gov/niosh/ipcs/icstart.html

Sigma Aldrich

• http://www.sigmaaldrich.com/safety-center/globally-harmonized.html

EU List of Chemicals with Classification

• http://echa.europa.eu/web/guest/information-on-chemicals/cl-inventory-database

New Zealand List of Chemicals with Classification

• http://www.epa.govt.nz/search-databases/Pages/HSNO-CCID.aspx

Japan List of Chemicals with Classification

• http://www.safe.nite.go.jp/english/ghs_index.html#results

How do you plan on providing GHS training on labels and SDS to your campus?

A •Live training classes

B •Handouts

C •On-line mandatory training

QUESTIONS?

Contact:Kim Gates Auletta

Environmental Health & SafetyStony Brook University

Kim.auletta@stonybrook.edu631-632-3032

http://www.stonybrook.edu/ehs/lab/