pesticide education program globally harmonized system (ghs) change from material safety data sheet...

Pesticide Education Program

Globally Harmonized System (GHS)Change from

Material Safety Data Sheet (MSDS)to

Safety Data Sheet (SDS)


Objectives

• History of GHS• Major Changes Under GHS• What Do You Need to Do• Step by Step Compliance


• An international mandate to harmonize labels was adopted at the United Nations Conference on the Environment and Development (UNCED) in 1992 in Brazil:– A globally-harmonized hazard classification and

compatible labeling system, including material safety data sheets and easily understandable symbols, should be available, if feasible, by the year 2000.

History of GHS


In March 2012, Occupational Safety and Health Administration (OSHA)

published a final rule to align its Hazardous Communication

Standards (HCS) regulations with the Globally Harmonized System (GHS)

of Classification and labeling of chemicals


The primary goal of GHS is improved protection of human health and the environment by providing chemical users and handlers with enhanced

and consistent information on chemical hazards.


The GHS is based on major existing systems for industrial chemicals,

pesticides, consumer chemicals, and chemicals in transport, but

implementation of the GHS would require some changes in all existing

systems in order to achieve harmonization.


However, it is important for growers who use Federally regulated pesticides to note that the Environment Protection Agency (EPA) has NOT yet moved to amend its pesticide labeling regulations under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to align with the GHS.


Under the HazCom 2012, the MSDS will be replaced with a Safety Data

Sheet (SDS).

Why the switch from MSDS to SDS?


Why the switch from MSDS to SDS? • Before the HazCom 2012, there were several

acceptable MSDS formats. OSHA’s adoption of Global Harmonization Standards (GHS) requires the use of a single format.

• All SDS will have 16 sections that appear in a specific order.


Major Changes Under GHS


• MSDS to SDS Format• Labeling Requirements/Pictograms• Hazard Classification

Changes


• MSDS to SDS Format– MSDS will now be referred to as Safety Data

Sheets

– There is now a specified 16-section format that must be followed.

Changes


Section 1Identification of Substance and Supplier


Section 2Hazard Identification


Section 3Composition/Information on Ingredients


Section 4First Aid Measures


Section 5Firefighting Measures


Section 6Accidental Release Measures


Section 7Handling and Storage


Section 8Precautions to Control Exposure/Personal

Protection


Section 9Physical and Chemical Properties


Section 10Stability and Reactivity


Section 11Toxicological Information


Section 12Ecological Information


Section 13Waste Disposal Consideration


Section 14Transportation Information


Section 15Regulatory Information


Section 16Other Information


Pictograms


Pictograms

• Health Hazard– Carcinogen– Respiratory sensitizer– Reproductive toxicity– Target Organ toxicity– Mutagenicity– Aspiration toxicity


Pictogram

• Flame– Flammables– Self-Reactives– Pyrophorics – Self-Heating– Emits flammable gas– Organic peroxides


Pictograms

• Exclamation Mark– Skin and eye irritant– Skin sensitizer– Acute toxicity – Narcotic effects– Respiratory tract irritant


Pictograms

• Gas Cylinder– Gas Under Pressure

• Flames Over Circle– Oxidizer


Pictograms

– Corrosion• Corrosives

– Skull and Crossbones – Acute Toxicity (Severe)


Pictograms

• Exploding Bomb– Explosives– Self-Reactive– Organic peroxides


Pictograms

• Environment– Aquatic Toxicity


• The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures

• These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result

Hazard Classification


Will the change require that both and MSDS and an SDS be kept for the same product? • For compliance with the new OSHA HazCom 2012

regulatory requirements, maintaining both an MSDS and a SDS for the same chemical is not necessary.

• As the SDS becomes available for individual products, they will replace the existing MSDSs.

• Although there is no requirement to keep the older MSDS once it is replaced with an SDS, a good management practice would be to keep an electronic copy on file, especially if existing stocks of the chemical were purchased under the older MSDS.


Will the change require that both and MSDS and an SDS be kept for the same product? • When the chemical in question is a pesticide

and the content of the MSDS and the SDS differs, a copy of both documents must be maintained to ensure compliance with OSHA HazCom 2012 and FIFRA which regulates pesticide products.


The differences between EPA’s current requirements and the GHS are related to classification criteria, hazard statements, pictograms, and

signal words.


For example, FIFRA pesticide product labels may contain the following signal words: of “Danger Poison with the skull and crossbones graphic,” “Warning,” or

“Caution” depending on the toxicity level of the product, and “Danger” for a product that may be a potential skin or

eye irritant.


The GHS uses only two signal words, “Danger” and “Warning.”


How this may cause a problem for example is the label of a chemical that has an oral LD50 of 550 mg/kg

bears the signal word “Caution” under current FIFRA labeling

practices but would require the signal word “Warning” under the

GHS Safety Data Sheet format.


For pesticide products, FIFRA labels approved by EPA pre-empt OSHA’s

label requirements, but not the requirements for SDS and worker

training (except for certified applicators and agricultural workers

for whom EPA has training requirements).


EPA realizes that this may require users of the SDS that are prepared for

pesticide products to become familiar with two different systems, at least

until the agencies’ requirements are harmonized.


As a result, EPA issued guidance in the April 20, 2012 Federal Register to

manufactures so that when changes are made to the SDS to meet the OSHA requirements, the new SDS format will

also be in compliance with the pesticide regulations under FIFRA.


Will the change require that both and MSDS and an SDS be kept for the same product?

• When the chemical in question is a pesticide and the content of the MSDS and the SDS differs, a copy of both documents must be maintained to ensure compliance with OSHA HazCom 2012 and FIFRA which regulates pesticide products.


HazCom 2012 Compliance Dates and Deadlines:

There is a 3 year phase in period through 2016



• December 1, 2013 – – Employers must train employees on how to read

GHS formatted labels and SDS’s. – Changes to labels are probably more substantial,

however, employees need to understand where to find information on the SDS.



• 2013 – 2015 On an Ongoing Basis – – Employers should replace existing MSDSs with

new SDSs as they become available. – For pesticide products, employers must be sure

to determine if there are any differences between the MSDS and SDS. If differences exist, a copy of the MSDS must also be maintained to be in compliance with both HasCom2012 and FIFRA.



• June 1, 2015 – Chemical manufacturers and distributors should have completed their reclassification of chemicals and be shipping GHS formatted SDS and labels with their shipments.



• December 1, 2015 – Distributors have an additional 6 months beyond the June 1, 2015 date to pass along manufacturer labels and SDSs in the older formats. However, beyond December 1, 2015, all MSDSs and labels in the U.S. should be in compliance with HazCom 2012 provisions.



• June 1, 2016 –– Employers should be fully compliant with

HazCom 2012. That includes making any necessary updates to their HazCom program, training employees on any newly identified chemical hazards (identification of new hazards is likely during the reclassification process chemical manufacturers undertake), and updating SDS libraries and secondary labels.


This presentation was created in partnership with the Pesticide Education Program, Penn State Cooperative Extension;

and the Pennsylvania Department of Agriculture.

For more information on this and other resources, please visit

extension.psu.edu/pested

Where trade names appear, no discrimination is intended, and no endorsement by Penn State Cooperative Extension is implied.Penn State is committed to affirmative action, equal opportunity, and the diversity of its workforce.

© The Pennsylvania State University 2012 November 2012

pesticide education program globally harmonized system (ghs) change from material safety data sheet...

Documents

storage slide

reactivity slide

supplier slide

history of ghs slide

pesticide labeling regulations

ecological information

regulatory information

step compliance slide