1

OSHA Update

and the

Revised Hazard Communication

Standard

(GHS)

Triumvirate Environmental

OSHA Update

Top 10 Violations

1926.451 – Scaffolding

1926.501 – Fall

Protection

1910.1200 – Hazard

Communication

1910.134 – Respiratory

Protection

1910.147 –

Lockout/Tagout

1910.305 – Electrical,

Wiring Methods

1910.178 – Powered

Industrial Trucks

1926.1053 – Ladders

1910.303 – Electrical,

General Requirements

1910.212 – Machine

Guarding

2

Updates

Heat Campaign

Residential Falls

Needle sticks

Teen Workers Fed & State

Hearing Loss

Emergency Action Plans

Machine guarding

Laser Safety

Electrical Training & Equipment

Powered Industrial Trucks

Languages

Emphasis NEP, LEP, SST

Hazcom

National Campaigns

Heat

Residential Falls

Roll Outs Ladder Safety

Electric Cords

Needle Sticks

Needle sticks

3

Safer Needles

Training,

Training,

Training,

http:www.osha.gov to Young Workers

Young Workers

4

Young – Teen Workers

Hearing

Hearing Loss Whaaat ?

Hearing Protection

Quiz:

Action Level = ___ dB

PEL = ___ dB

STEL = ___ dB x ___

5

Emergency Action Plans

1910.38(a) Application. An employer must have an emergency action plan whenever an OSHA standard in this part requires one.

The requirements in this section apply to each such emergency action plan.

1910.38(b) Written and oral emergency action plans. An emergency action plan must be in writing, kept in the workplace, and

available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to

employees.

1910.38(c) Minimum elements of an emergency action plan. An emergency action plan must include at a minimum:

1910.38(c)(1) Procedures for reporting a fire or other emergency;

..1910.38 (c)(2)

1910.38(c)(2) Procedures for emergency evacuation, including type of evacuation and exit route assignments;

1910.38(c)(3) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate;

1910.38(c)(4) Procedures to account for all employees after evacuation;

1910.38(c)(5) Procedures to be followed by employees performing rescue or medical duties; and

1910.38(c)(6) The name or job title of every employee who may be contacted by employees who need more information about

the plan or an explanation of their duties under the plan.

1910.38(d) Employee alarm system. An employer must have and maintain an employee alarm system. The employee alarm

system must use a distinctive signal for each purpose and comply with the requirements in § 1910.165.

1910.38(e) Training. An employer must designate and train employees to assist in a safe and orderly evacuation of other

employees.

1910.38(f) Review of emergency action plan. An employer must review the emergency action plan with each employee covered by the plan:

1910.38(f)(1) When the plan is developed or the employee is assigned initially to a job;

1910.38(f)(2) When the employee's responsibilities under the plan change; and

1910.38(f)(3)

1

3

Emergency Action Plans

Emergency Action Plan must be in writing, onsite

Procedures for reporting a fire or other emergency

Evacuation, type of evacuation and exit route assignments

Employees who remain

Account for all employees after evacuation

Employees performing rescue or medical duties

Name employees for more information contact

Employee alarm system; have, maintain; distinctive signal, each purpose

Designate and train each employee assisting evacuation

Review EAP with each covered employee

§ 1910. 157 Fire Brigades 1910. 165 Employee Alarm Systems

1910. 120(q) Hazwoper – Emergency Response NFPA

Other Regulations……

1910. 157 Fire Brigades

1910. 165 Employee Alarm Systems

1910. 120(q) Hazwoper – Emergency Response

NFPA

6

Guarding & Electrical

Machine guarding

Hazard Analysis

Manufacturer

Nationally Recognized Standards

Electrical T raining

E quipment <Rated>

D ocumentation

D isciplinary Program <Positive , Progressive, >

Practices L O T O

Lasers Types

Laser Safety

Types of Lasers

There are many different types of lasers. The laser medium can be a solid, gas, liquid or semiconductor.

Lasers are commonly designated by the type of lasing material employed:

Solid-state lasers have lasing material distributed in a solid matrix (such as the ruby or neodymium:yttrium-

aluminum garnet "Yag" lasers). The neodymium-Yag laser emits infrared light at 1,064 nanometers (nm). A

nanometer is 1x10-9 meters.

Gas lasers (helium and helium-neon, HeNe, are the most common gas lasers) have a primary output of visible

red light. CO2 lasers emit energy in the far-infrared, and are used for cutting hard materials.

Excimer lasers (the name is derived from the terms excited and dimers) use reactive gases, such as chlorine

and fluorine, mixed with inert gases such as argon, krypton or xenon. When electrically stimulated, a pseudo

molecule (dimer) is produced. When lased, the dimer produces light in the ultraviolet range.

Dye lasers use complex organic dyes, such as rhodamine 6G, in liquid solution or suspension as lasing

media. They are tunable over a broad range of wavelengths.

Semiconductor lasers, sometimes called diode lasers, are not solid-state lasers. These electronic devices are

generally very small and use low power. They may be built into larger arrays, such as the writing source in

some laser printers or CD players.

Lasers- Classes

Class I: cannot emit laser radiation at known hazard levels (typically continuous wave: cw 0.4 µW at visible

wavelengths). Users of Class I laser products are generally exempt from radiation hazard controls during

operation and maintenance (but not necessarily during service).

Since lasers are not classified on beam access during service, most Class I industrial lasers will consist of a

higher class (high power) laser enclosed in a properly interlocked and labeled protective enclosure. In some

cases, the enclosure may be a room (walk-in protective housing) which requires a means to prevent operation

when operators are inside the room.

Class I.A.: a special designation that is based upon a 1000-second exposure and applies only to lasers that are

"not intended for viewing" such as a supermarket laser scanner. The upper power limit of Class I.A. is 4.0 mW.

The emission from a Class I.A. laser is defined such that the emission does not exceed the Class I limit for an

emission duration of 1000 seconds.

Class II: low-power visible lasers that emit above Class I levels but at a radiant power not above 1 mW. The

concept is that the human aversion reaction to bright light will protect a person. Only limited controls are

specified.

Class IIIA: intermediate power lasers (cw: 1-5 mW). Only hazardous for intrabeam viewing. Some limited controls

are usually recommended.

NOTE: There are different logotype labeling requirements for Class IIIA lasers with a beam irradiance that does

not exceed 2.5 mW/cm2 (Caution logotype) and those where the beam irradiance does exceed 2.5 mW/cm2

(Danger logotype).

Class IIIB: moderate power lasers (cw: 5-500 mW, pulsed: 10 J/cm2 or the diffuse reflection limit, whichever is

lower). In general Class IIIB lasers will not be a fire hazard, nor are they generally capable of producing a

hazardous diffuse reflection. Specific controls are recommended.

Class IV: High power lasers (cw: 500 mW, pulsed: 10 J/cm2 or the diffuse reflection limit) are hazardous to view

under any condition (directly or diffusely scattered) and are a potential fire hazard and a skin hazard. Significant

controls are required of Class IV laser facilities.

7

Lasers

Directive Brief Overview Directive Number: TED 01-00-015

Effective Date: 1/20/1999

Introduction

Nonbeam Laser Hazards

Biological Effects of the Laser Beam

Laser Hazard Classifications

Investigational Guidelines

Control Measures and Safety Programs

Bibliography

→Controls

» Engineering controls

» Personal Protective Equipment

» Administrative

» Procedural controls

» Special controls

Lasers – VI. Control Measures and

Safety Programs

ANSI Z 136.1 (1993): FOR THE SAFE USE OF LASERS

ANSI Z 136.3 (1988): "FOR THE SAFE USE OF LASERS IN HEALTH CARE FACILITIES"

ANSI/NFPA 70-1990: THE NATIONAL ELECTRICAL CODE - 1990 HANDBOOK

ANSI Z 87.1 (1989): "PRACTICE FOR OCCUPATIONAL AND EDUCATIONAL EYE AND FACE PROTECTION"

A. CLASS I, CLASS II, CLASS I.A., AND CLASS IIIA LASERS.

B. LASER SAFETY OFFICER (LSO).

C. BEAM PATH CONTROLS

D. LASER-CONTROLLED AREA

E. CLASS IV LASER CONTROLS--GENERAL REQUIREMENTS.

F. ENTRYWAY CONTROL MEASURES (CLASS IV)

G. TEMPORARY LASER-CONTROLLED AREA.

H. ADMINISTRATIVE AND PROCEDURAL CONTROLS

I. ENGINEERING CONTROLS

J. LASER USE WITHOUT PROTECTIVE HOUSING (ALL CLASSES)

H. OPTICAL FIBER (LIGHT WAVE) COMMUNICATION SYSTEMS (OFCS)

Lasers - Signs

8

Lasers

2

2

P I T s

Powered Industrial Trucks

T raining

E quipment

D ocumentation

D iscipline *

Special Programs

Emphasis Examples

NEP Dust

LEP Falls/MAST Climbers

SST Fishing Industry

UTenn <Dodge> Random

9

Language

Languages

Spanish

Portuguese

Vietnamese

Other

Communication

Training

Qualification

Understanding

Language Initiatives

Language Target Groups

Channel

Portuguese Alliance Groups

Spanish Community

Vietnamese Consulates

Other(s) Trades

Schools

Youth Work Sites

Social Media

·

Analyze

Applicable issues – Methods to Resolve

Let’s look at . . .

Top 10 Violations

CAS Activities

Pathways to Success . . . <all paid for>

2

7

10

Let’s Take a Short Break!

Revised Hazard Communication

Standard

Why is GHS Needed?

No country has the ability to identify and

specifically regulate every hazardous

chemical product

For example, in the United States, there

are an estimated 945,000 such products

Adoption of requirements for information

to accompany the product helps address

protection needs

11

Why is GHS Needed? (cont.)

Countries with systems that address

these needs have adopted different

requirements for hazard definitions as

well as information to be included on a

label or material safety data sheet.

This impacts both protection and trade.

An estimated 41 million employees are

potentially exposed to hazards

chemicals

Why Does OSHA want this?

OSHA's Hazard Communication Standard

(HCS) has performance-oriented

requirements for labels and safety data

sheets

Hazard communication is often

inconsistent as a result

Users of labels and safety data sheets

would prefer a standardized approach

Adoption of the GHS would address this

domestic concern

Major Revisions to the HCS

Hazard Classification – Provides specific

criteria for classification of health and

physical hazards, as well as classification

of mixtures and chemicals

Labels – Chemical manufactures and

importers will be required to provide a label

that includes a harmonized signal word,

pictogram, and hazard statement for each

hazard class and category. Precautionary

statements must also be provided.

12

Major Revisions to the HCS

Safety Data Sheets – Will now be

required to be in the 16 part format

Information and Training – All

employers are required to train

workers on the new labels, elements

and safety data sheets format

Refined definitions of Flammable

Liquids and Toxicity

What is the primary benefit?

The primary benefit of the revised standard

is to increase the quality and consistency of

information provided to workers, employers

and chemical users by adopting a

standardized approach to hazard

classification, labels and safety data.

Estimated to prevent 43 fatalities and 521

injuries and illness per year.

What are the primary benefits?

OSHA estimates that the monetized health

and safety benefits of the final rule are $250

million annually and that the annualized

cost reductions and productivity gains are

$507 million annually.

The revised standard provides a single set

of harmonized criteria for classifying

chemicals according to their health and

physical hazards

13

What are some key terms in the

Revised Standard?

SDS - Safety Data Sheet. SDS is the term

used by GHS for Material Safety Data Sheet

(MSDS).

Hazard Category – These categories

compare hazard severity within a hazard

class

Classification - is the term used to describe

the different hazards.

What are some key terms in the

GHS Vocabulary?

Hazard Statement - For each category of a

class, a standardized statement is used to

describe the hazard. The hazard statement

would appear both on the label and on the

SDS.

Signal word - There are two signal words in

the GHS system - Danger and Warning.

There are categories where no signal word

is used.

What are some key terms in the GHS

Vocabulary?

Pictogram - Pictogram refers to the GHS

symbol on the label and SDS. Not all

categories have a symbol associated with

them.

14

New – Flammable Liquid

OSHA deleted the term “Combustible

Liquid”

Flammable liquid means any liquid having a

flashpoint at or below 199.4 [deg]F (93

[deg]C).

New Flammable Liquid

Flammable liquids are divided into four

categories as follows: Category 1 shall include liquids having flashpoints below 73.4F

and boiling point at or below 95F.

Category 2 shall include liquids having flashpoints below 73.4F

and a boiling point above 95F

Category 3 shall include liquids having flashpoints at or above

73.4 F and at or below 140F.

Category 4 shall include liquids having flashpoints above 140F

and at or below 199.4F

Flammable Liquid Storage

Container

Type

Category 1 Category 2

Category 3

Category 4

Glass or

Approved

Plastic

1 pint 1 quart 1 gallon 1 gallon

Metal (other

than DOT

drums)

1 gallon 5 gallons 5 gallons 5 gallons

Safety Cans 2 gallons 5 gallons 5 gallons 5 gallons

Metal Drums

(DOT

approved)

60 gallons 60 gallons 60 gallons 60 gallons

Approved

Portable Tanks

660 gallons 660 gallons 660 gallons 660 gallons

15

What are the classes within the

Health hazard group?

Acute toxicity

Skin corrosion/irritation

Serious eye

damage/eye irritation

Respiratory or skin

sensitization

Germ cell mutagenicity

Aspiration hazard

Carcinogenicity

Reproductive toxicity

Specific target organ

toxicity - single

exposure

Specific target organ

toxicity - repeated

exposure, and

What are the classes within the

Physical hazard group?

Explosives

Flammable gases/aerosols

Oxidizing gases

Gases under pressure

Flammable liquids/solids

Self-reactive substances

and mixtures

Corrosive to metals

Pyrophoric

liquids/Solids

Self-heating substances

and mixtures

Substances and

mixtures which, in

contact with water, emit

flammable gases

Oxidizing liquids/Solids

Organic peroxides

Example Labels

16

Flammable Liquid

•Flammables

•Pyrophorics

•Self-Heating

•Emits Flammable Gas

•Self-Reactives

•Organic Peroxides

Exploding Bomb

•Explosives

•Self-Reactives

•Organic Peroxides

Corrosive

•Skin Corrosion/Burns

•Eye Damage

•Corrosive to Metals

17

Irritant

•Irritant (skin and eye)

•Skin Sensitizer

•Acute Toxicity

•Narcotic Effects

•Respiratory Tract Irritant

•Hazardous to Ozone Layer

(Non-Mandatory)

Flame Over Circle

•Oxidizers

Gas Cylinders

•Gases Under Pressure

18

Skull and Crossbones

•Acute Toxicity (fatal or toxic)

Health Hazard

•Carcinogen

•Mutagenicity

•Reproductive Toxicity

•Respiratory Sensitizer

•Target Organ Toxicity

•Aspiration Toxicity

Environment (Non-Mandatory)

•AQUATIC TOXICITY

19

Signal Words

Signal Words

The final rules requires the use of only two

signal words for labels

»Danger

»Warning

Danger is used for the more sever hazards

Warning denotes less of a hazard

Regulated Chemicals Signal Words

OSHA has revised the regulated signage for

substance specific health standard

materials

These include, but are not limited to the

following materials: Asbestos

Lead

Cadmium

Ethylene Oxide

Formaldehyde

Benzene

20

Safety Date Sheets

Safety Data Sheets

The safety data sheet should provide

comprehensive information about the

chemical that allows employers and

workers to obtain concise, relevant and

accurate information that can be put in

perspective with regard to the hazards,

uses and risk management of the chemical

product in the workplace.

Safety Data Sheets

The SDS must contain 16 sections. While

there were some differences in existing

industry recommendations, and

requirements of countries, there was

widespread agreement on a 16 section SDS

that includes the following headings in the

order specified:

21

Safety Data Sheets

Identification

Hazard(s) identification

Composition/ information

on ingredients

First-aid measures

Fire-fighting measures

Accidental Release

Measures

Handling and storage

Transport information

Regulatory information

Handling and storage

Exposure control/ personal

protection

Physical and chemical

properties

Stability and reactivity

Toxicological information

Ecological information

Disposal considerations

Transport information

Regulatory information

Other information.

Hazard and Precautionary

Statements

Hazard and Precautionary Statements

Hazard Statements describe the

hazards associated with a

chemical

Precautionary Statements describe

recommended measures that

should be taken to protect against

hazardous exposures, or improper

storage or handling of a chemical

22

Hazard and Precautionary Statements

OSHA has stated that standardizing

the requirements for hazard and

precautionary statements will provide

a degree of consistency that is lacking

among the current chemical labels.

Example New Posting for

Formaldehyde

DANGER

Formaldehyde

Irritant and

Potential Cancer

Hazard

Authorized

Personnel Only

DANGER

Formaldehyde

May Cause Cancer

Causes Skin, Eye,

and Respiratory

Irritation

Authorized

Personnel Only

Example GHS Inner Container Label (e.g.,

bottle inside a shipping box)

ToxiFlam (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 Material Safety Data Sheet for further details regarding safe use of this product.

MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999

23

Example GHS Outer Container Label (55

gallon/200 liter drum)

Flammable liquids, toxic, n.o.s.

Danger! Toxic If Swallowed Flammable Liquid and Vapor (contains XYZ)

UN 1992 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 Material Safety Data Sheet for further details regarding safe use of this product.

MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999

Training Requirements

Training Requirements

The new standard does not impose

employee training requirements; however,

OSHA believes that additional training will

be necessary to ensure that employees

understand the new elements, particularly

on the new pictograms.

Therefore, modified training requirements

have been included in the final rule in order

to address the new label elements and SDS

format required under this revised standard.

24

Training Requirements

Employers shall provide employees with

effective information and training on

hazardous chemicals in their work area at

the time of their initial assignment, and

whenever a new chemical hazard the

employees have not previously been trained

about is introduced into their work area.

Information and training may be designed

to cover categories of hazards (e.g.,

flammability, carcinogenicity) or specific

chemicals.

Training Requirements

OSHA estimates that employee training will

take up to:

One Hour per production employee in

most industries

Thirty minutes in occupations exposed to

a few hazardous chemicals and types of

hazards

Ten minutes per employee in some

occupations where GHS-type pictograms

are already in use

Important Dates to Remember

25

Important Dates to Remember

December 31, 2013. Employers must train

employees on the new label elements contained in

the standard and the new format for Safety Data

Sheets.

June 1, 2015. Chemical manufacturers, importers,

distributors and employers must comply with all

modified provisions of the revised Hazard

Communication Standard except that distributors

of chemicals covered by the standard are allowed

to ship products, labeled by manufacturers under

the old system, until December 1, 2015.

Important Dates to Remember

June 1, 2016. Employers are required to

update alternative workplace labeling and

their written Hazard Communication

Program to bring them into full compliance

with the revised standard and to provide

additional training for newly identified

physical or health hazards.

Other OSHA Regulations Affected

Laboratory Standard

Need to update the definitions

Hazardous Waste Operations and Emergency

Response

Need to update definitions

Need to train on the new labels, physical and health hazards

Spray finishing

New flammable liquid requierments

Welding, Cutting and Brazing

Changes to the Substance Specific Standards (lableling)

26

Other U.S. Agencies Effected

The Department of Transportation (DOT),

Environmental Protection Agency (EPA), and the

Consumer Product Safety Commission (CPSC)

were actively involved in developing the GHS.

DOT has already modified their requirements for

classification and labeling to make it consistent

with international UN transport requirements and

the GHS.

Questions??

Thank you

Rick Foote

Consulting Services Manager, Industrial

617-686-6184

rfoote@triumvirate.com