the revised hazard communication standard 29 cfr 1910.1200 final rule march 26, 2012 safety data...

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The Revised Hazard Communication

Standard29 CFR 1910.1200

Final Rule March 26, 2012Safety Data Sheets and Labels

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DisclaimerThis presentation was prepared using the Final Rule published in the Federal Register 26 Mar 2012. The interpretation is the author’s. It is based on information available as of June 1, 2013. While it is provided in good faith and based on the best information available as of June 1, 2013, it is to be relied upon at the user’s own risk.

No representations or warranties are made regarding completeness or accuracy and no liability will be accepted by the author resulting from use of or reliance on this presentation.

Compliance with OSHA is the employer’s responsibility. See www.osha.gov for the complete Rule.

http://www.osha.gov/

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Hazard Communication - 2012

• On March 26, 2012, the revised OSHA Hazard Communication Standard, 29 CFR 1910.1200 was published in the Federal Register.

• The new standard aligns the U.S. Hazard Communication Standard with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

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As a result of the new HAZCOM Rule

• Material Safety Data Sheets (MSDS) will be now be called Safety Data Sheets (SDS)

• Content of the SDS and Label are mandated• Labels will change• Pictograms or icons will be used to indicate hazardsThis HAZCOM Rule is OSHA’s adoption of the “Globally Harmonized System (GHS)” promulgated by the UN

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What is GHS?

• GHS is the United Nations (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

• Initiated at the UN Rio de Janeiro Conference on the Environment and Development in 1992

• Intent was to provide a framework for countries to develop rules for communication of hazards of chemicals, harmonize the communication of hazards between countries by standardizing the classification of hazards and defining the content of that communication of hazards

The Purple Book

http://www.barnesandnoble.com/w/globally-harmonized-system-of-classification-and-labeling-of-chemicals-united-nations/1100086904?ean=9789211170429

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Why GHS?

• The benefits of standard communication were hoped to be– Improved protection of human health– Greater consistency in communication of hazard

information through label elements and safety data sheets (SDSs)

– Increased efficiencies, reduced costs of compliance (more standardized approach across geographies and regions)

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As of 2011, 67 countries have implemented or started implementation of GHSBlue Countries where GHS has not been implementedYellow Countries in the process of implementing GHS

Light Green Countries where GHS is voluntaryDark Green Countries that have implemented GHS

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GHS Implementation in the USA began with the HAZCOM Final Rule, Mar 26, 2012

• United States (OSHA) Compliance Dates:– December 1, 2013 - Employee training on safety data sheet format and

new label elements.

– June 1, 2015 - Out-going chemicals and products will need to be labeled according to the revised requirements and safety data sheets will have to conform to the new format.

– December 1, 2015 – Distributors shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label.

– June 1, 2016 - Workplace labeling and written hazard communication programs are required to be revised.

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Globally Harmonized System (GHS) for the Classification and Labeling of Chemicals

• Is a set of guidelines for ensuring the safe production, transport, handling, use and disposal of hazardous materials, developed by the United Nations, as a way to bring into agreement the chemical regulations and standards of different countries.

• OSHA adopted GHS on March 26, 2012, with the promulgation of the Revised Hazard Communication Standard.

• OSHA did not adopt the UN system in whole.

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OSHA did not adopt all of the GHS rules as outlined in the UN Purple Book

• Countries are allowed to “pick and choose” from the guidelines in the UN Purple Book

• Result is some differences between SDS and labels, country to country

• European SDS are more like the UN guidelines


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Example: Acetic Acid comparison of Hazard (Risk) and Precautionary (Safety) phrases adopted

EU SDSRISK PHRASES :

– R-10 Flammable– R-35 Causes severe burns

SAFETY PHRASES: – S-23 Do not breathe

gas/fumes/vapour/spray– S-26 In case of contact with

eyes, rinse immediately with plenty of water and seek medical advice

– S-45 In case of accident or if you feel unwell, seek medical advice immediately

US SDSHazard Statements

– Causes severe skin burns and eye damage– Flammable liquid and vapor

Precautionary Statements -Prevention– Keep away from heat/sparks/open flames – No

Smoking– Keep container tightly closed– Ground/bond container and receiving equipment – Use explosion-proof electrical– Use non-sparking tools– Take precautions against static discharges– Wear protective gloves/clothing and eye/face

protection

Precautionary Statements - Response– If on skin, take off immediately contaminated

clothing. Rinse skin with water– In case of fire, use…

Precautionary Statements - Storage– Store in a well-ventilated area– Keep cool

Precautionary Statements - Disposal– Dispose of contents or containers in accordance with

EPA regulations.

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Globally Harmonized System (GHS) for the Classification and Labeling of Chemicals

• Countries can pick and choose those pieces of the GHS they wish to incorporate into their own regulations Each adopting country is solely responsible for its enforcement within its jurisdiction.

• The biggest changes are to safety labels and safety data sheets. • GHS is meant to be a logical and comprehensive approach to:

– Defining health, physical and environmental hazards of chemicals (although environmental hazards are outside OSHA’s jurisdiction)

– Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria

– Communicating hazard information in a prescribed and uniform way on labels and safety data sheets


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In the U.S., adoption of GHS is under the jurisdiction of 4 Agencies:

• Department of Transportation (DOT) - done– The DOT was actually the first agency to implement GHS

• Occupational Safety & Health Administration (OSHA) - done– OSHA served as the lead U.S. agency on the classification of

chemicals and hazard communication• Environmental Protection Agency (EPA) – to come

– The EPA is expected to follow closely on the heels of OSHA’s adoption with revisions to its own standards to bring them into alignment with GHS.

• Consumer Product Safety Commission (CPSC) – starting to consider GHS for consumer products


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Significant changes to the Hazcom Standard

• Requires:– Chemical Hazard Classification by the rules given in the

Appendices to the standard– Hazard Label Elements (Pictogram, Hazard Statements and

Precautionary Statements) must be used on the label and SDS

– Safety Data Sheet (SDS) format

• Significant impact on chemical manufacturers and importers as substances and mixtures will need to be classified according to the rule


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Organization of the New Hazcom Standard

a. Purposeb. Scope and Applicationc. Definitionsd. Hazard Classificatione. Written Hazard

Communication Program

f. Labels and Other Forms of warning

g. Safety Data Sheetsh. Employee Information

and Trainingi. Trade Secretsj. Effective Dates

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Appendices

• A (Mandatory) – Health Hazard Criteria• B (Mandatory) – Physical Hazard Criteria• C (Mandatory) – Allocation of Label Elements• D (Mandatory) – Safety Data Sheets• E (Mandatory) – Definition of Trade Secret• F (non-Mandatory) – Guidance for Hazard

Classifications Re: Carcinogenicity


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Compare the Old HAZCOM Standard to the New One

What is the same:• Employers must have a written

HAZCOM program• Manufacturer or importer must

provide the hazard information on a document

• Hazardous chemicals in the workplace must be labeled (still exemption for immediate use container)

• Employers required to train employees on hazardous chemicals in the workplace

What is different:• Hazard information document

(SDS) from the manufacture must follow certain rules

• Hazardous chemicals must be classified according to rules, classification then dictates hazard pictograms or icons, Signal Words, Hazard Statements and Precautionary statements that must be on the SDS and the label

• Contents of label specified

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What are the significant requirements of the new Hazcom Standard?

• Manufacturers must classify the hazards of the materials they produce according to rules provided in Appendices A and B

• Employers must have a written Hazard Communication Program

• Each container of hazardous material leaving the workplace must be labeled according to rules provided in Appendix C


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What are other requirements of the new Hazcom Standard?

• Manufacturers must develop Safety Data Sheets that include the information specified in Appendix D and using the hazard classification system in Appendices A and B, and the pictograms, signal words, and phrases required by Appendix C

• Employers must provide effective training for employees on the hazards of chemicals used in the workplace, methods and observations that may be used to detect the presence or release of a chemical, and measures employees can use to protect themselves.


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Definitions

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Definitions

• Hazardous chemical – any chemical which is classified as a physical hazard or a health hazard, simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

29 CFR 1910.1200(c)


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Definitions

• Health hazard – a chemical which is classified as posing one of the following hazardous effects: acute toxicity, skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization, germ cell mutagenicity; carcinogenicity, reproductive toxicity, specific target organ toxicity or aspiration hazard.

29 CFR 1910.1200(c)


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Definitions

• Physical hazard – a 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; self-heating; organic peroxide; corrosive to metal; gas under pressure ; or in contact with water emits flammable gas.

29 CFR 1910.1200(c)


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Definitions

• Classification – Identify the relevant data on the hazards of a chemical to determine if it is hazardous (by definition) and the degree of hazard

• Hazard class – the nature of the physical or health hazards (such as, ‘flammable’)

• Hazard category – the division of criteria within a hazard class (e.g. flammable liquids hazard class contains 4 categories depending on the severity of the hazard)

29 CFR 1910.1200(c)


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Definitions

• Hazard statement – a statement assigned to a hazard class and category that describes the nature of the hazard

• Precautionary statement – a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure, improper storage or handling of a hazardous chemical

• Signal word – a word used to indicate the relative severity of hazard on the label and SDS29 CFR 1910.1200(c)


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Definition

• Pictogram means a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are designated under this standard for application to a hazard category.

29 CFR 1910.1200(c)


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Definition needed when we discuss Labels

• Container – any bag, barrel, bottle, box, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical (pipes or piping systems and engines, fuel tanks or other operating systems are not containers)

29 CFR 1910.1200(c)


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Written Program

29 CFR 1910.1200(e)

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Written Program

• Employers are required to develop, implement, and maintain at each workplace, a written hazard communication program which– Describes how the criteria for labeling, Safety Data Sheets

and training will be met– Includes a list of the hazardous chemicals in the workplace– The methods the employer will use to inform employees of

the hazards of non-routine tasks– The methods used to provide information, SDS, labels and

precautionary measures to other employers on multi-employer worksites

29 CFR 1910.1200(e)


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Written Program

• The employer can rely on the current program as long as it meets the criteria in the revised Hazcom standard

• The written program has to available• Where employees travel between workplaces

during a shift, the program may be kept at the primary workplace.


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Training

29 CFR 1910.1200(h)

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Training

• Employers shall provide employees with effective information and training on hazardous chemicals in the work area– When: at time of initial assignment and whenever

a new chemical hazard is introduced

29 CFR 1910.1200(h)


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Training

• Information shall include:– The requirements of the standard– Operations where hazardous chemicals are

present– Location and availability of the written Hazcom

program including the inventory of hazardous chemicals


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Training

• Training shall include:– Methods and observations that may be used to detect

the presence or release of a hazardous chemical– Physical, health, simple asphyxiant, combustible dust,

and pyrophoric gas hazards and hazards not otherwise classified

– Measures employees can take to protect themselves from these hazards (work practices, emergency procedures, and PPE)

– Details of the Hazcom program including an explanation of labels, SDS and other hazard information


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Classification and Categorization

29 CFR 1910.1200(d) and Appendices A-C

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Classification

Even if you are not a manufacturer and will not be classifying any substances or mixtures, it is beneficial to have some understanding of

the classifications and categorization


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Under the new rules, a chemical must be classified and categorized according to its hazards.

The specific hazard and the category (severity) of that hazard dictates the

– Pictogram or icon– Signal word Hazard statements– Precautionary statements

These will appear on the SDS and the Label



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Classification

• Classification – determination of the hazards and the severity of the hazards (Categorization) dictates the– Signal Word– Pictograms– Hazard Statements– Precautionary Statements



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Hazard Classification

• The manufacturer must determine the hazardous effects (if any) in each Hazard Class, and Categorize by number within each Class

• Each of the Hazard Classes has a Pictogram which MAY be assigned depending on the Category within the Class



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Hazard Classifications which must be considered:

• Acute toxicity: • Skin corrosion/irritation: • Serious eye damage/eye irritation • Respiratory or skin sensitization: • Germ cell mutagenicity: • Carcinogenicity: • Reproductive toxicity: • Specific target organ toxicity-single exposure: • Specific target organ toxicity-repeated exposure: • Aspiration hazard:


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The Severity of the Hazard within each Class is defined by assigning the chemical to a

Category:• Acute toxicity: Category 1-4 • Skin corrosion/irritation: Category 1 (A-C) & Category

2 • Serious eye damage/eye irritation Category 1, 2A, 2B • Respiratory or skin sensitization: Category 1A, 1B • Germ cell mutagenicity: Category 1A, 1B, 2 • Carcinogenicity: Category 1A, 1B, 2 • Reproductive toxicity: Category 1A, 1B, 2 & effects via lactation • Specific target organ toxicity-single exposure: Category 1-3 • Specific target organ toxicity-repeated exposure: Category 1-2 • Aspiration hazard: Category 1

Appendix C


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Physical Hazards Classes that must be considered

• Explosives• Flammable Gases• Flammable Aerosols• Oxidizing Gases• Gases Under Pressure• Flammable Liquids• Flammable Solids• Self reactive Chemicals• Pyrophoric Liquids• Pyrophoric Solids


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Physical Hazards Classes that must be considered

• Self-Heating Chemicals• Chemicals which, in contact with Water, emit

Flammable Gases• Oxidizing Liquids• Oxidizing Solids• Organic Peroxides• Corrosive to Metals• Combustible Dust• Other Hazards not Specified, such as Asphyxiant


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The Severity of the Hazard within each Class is defined by assigning the chemical

to a Category:

• Explosives Categories 1.1 to 1.6• Flammable Gases Categories 1-2• Flammable Aerosols Categories 1-2• Oxidizing Gases Category 1• Gases Under Pressure Compressed, Liquefied, Dissolved, Refrigerated liquefied

• Flammable Liquids Categories 1-4• Flammable Solids Categories 1-2• Self reactive Chemicals Categories A-F• Pyrophoric Liquids Category 1• Pyrophoric Solids Category 1

Appendix C


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• Self-Heating Chemicals Categories 1-2• Chemicals which, in contact with Water, emit Flammable Gases

Categories 1-3• Oxidizing Liquids Categories 1-3• Oxidizing Solids Categories 1-3• Organic Peroxides Categories A-F• Corrosive to Metals Category 1• Pyrophoric Gas No Category• Combustible Dust No Category• Other Hazards not Specified, such as Asphyxiant No

Category

The Severity of the Hazard within each Class is defined by assigning the chemical

to a Category:

Appendix C


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Example: Acetic Acid, the Flammable Liquid Pictogram is required for Categories 1, 2 and 3

Hazard Classes have ‘Categories’

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The lower the Category number, the more severe the hazard within

a hazard class

Very Importa

nt

This is opposite of the convention of NFPA and HMIS labeling.

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A chemical is classified and categorized for each hazard that it presents

• Example: Benzene– Classified as a Carcinogen, Category 1A– Classified as Flammable , Category 1– Classified as a Skin Irritant, Category 2

• Multiple Pictograms required• Use the “worst case” Signal Word, in this case “Danger”

(Categories 1A Carcinogen and 1 for Flammable require this Signal word)

• Use Hazard Statements for all Hazard Classes identified• Include Precautionary Statements for all Hazard Classes

identified29 CFR 1910.1200(d) and Appendices A-C


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Example : Benzene

• Classified as a Carcinogen, Category 1A

• Classified as Flammable , Category 1

• Classified as a Skin Irritant, Category 2 --

Requires these Pictograms

This pictogram would be used UNLESS the health hazard pictogram is required, which in this case, it is.


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Example: Acetic Acid

The hazards are: • Corrosive to skin and metal• Flash Point 103oF (39oC)• Serious eye damage possible

Based on the hazards, the Classification and Categories would be assigned as follows:• Skin corrosion - Category 1 • Flammable Liquid - Category 3• Irreversible eye effects - Category 1• Acute Toxicity Dermal - Category 4• Acute Toxicity Inhalation - Category 4


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Example: Acetic Acid

• Skin corrosion - Category 1 • Flammable Liquid - Category 3• Irreversible eye effects - Category 1These Categories require Pictograms to indicate the hazard level within the hazard class:

To indicate Corrosive hazard and Irreversible eye effects

To indicate Flammability


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Example: Acetic Acid, the Flammable Liquid Pictogram is required for Categories 1, 2 and 3

Hazard Classes have ‘Categories’

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To understand the details, must read the SDS

• Category 1, Flash Pt < 73oF, IBP < 95oF• Category 2, Flash Pt < 73oF, IBP > 95oF• Category 3, Flash Pt > 73oF, but < 140oF

Note all of these will have the same Pictogram

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The Hazard Class and Category dictates which Pictogram to use. In some cases, if the

Category number indicates less hazard, no pictogram may be assigned.

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The pictogram assigned must be used both on the SDS and on the Label

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Note: OSHA requires use of only eight Pictograms. The Environment Hazard Pictogram is NOT REQUIRED by OSHA

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Prior to the GHS, MSDS used Signal Words such as these to indicate Toxicity

Table 1: Toxicity Classes: Hodge and Sterner Scale Routes of Administration

Oral LD50 Inhalation LC50

Dermal LD50

Toxicity Rating

Commonly Used Term

(single dose to rats) mg/kg

(exposure of rats for 4

hours) ppm

(single application to skin of rabbits) mg/kg

Probable Lethal Dose

for Man

1 Extremely Toxic

1 or less 10 or less 5 or less 1 grain (a taste, a drop)

2 Highly Toxic 1-50 10-100 5-43 4 ml (1 tsp)

3 Moderately Toxic

50-500 100-1000 44-340 30 ml (1 fl. oz.)

4 Slightly Toxic 500-5000 1000-10,000 350-2810 600 ml (1 pint)

5 Practically Non-toxic

5000-15,000 10,000-100,000

2820-22,590 1 litre (or 1 quart)

6 Relatively Harmless

15,000 or more

100,000 22,600 or more

1 litre (or 1 quart)

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The HCS Pictogram isn’t the whole storyHazard Class Oral Toxicity, Categories 1-3 have the

same Pictogram and Signal Word

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To understand the details, must read the SDS

• Category 1, LD50 < 5 mg/kg• Category 2, LD50 > 5 but < 50 mg/kg• Category 3, LD50 > 50 but <300 mg/kg

Note all of these will have the same Pictogram and the same Signal Word

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Test Yourself: Hazard Class Acute Oral Toxicity, what would be the Category for each of these chemicals? What would be the Pictogram and

Signal Word?

Rat, OralLD50 in mg/kg

Category

Strychnine 2.4Nicotine 50

Aspirin 200

Caffeine 192

Coumarin 293

Arsenic 763

Malathion 1375

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Answer: Hazard Class Acute Oral Toxicity, what would be the Category for each of these

chemicals?Rat, Oral

LD50 in mg/kgCategory

Strychnine 2.4 1Nicotine 50 2

Aspirin 200 3

Caffeine 192 3

Coumarin 293 3

Arsenic 763 4

Malathion 1375 4

All of these use the Signal Word “Danger” and the Pictogram:

These two use Signal Word “Warning” and Pictogram:

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Note: The Hazard Category Numbering

• Under GHS, the most hazardous Category within a Hazard Class is given the lowest number.

• A chemical with a Category 1 within a hazard class is more hazardous than a Category 3 in the same hazard class

Very Important

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NFPA and HMIS Numbering vs GHS

Under NFPA or HMIS ranking of hazards• A ranking of 4 means

the hazard is most severe in the hazard class

Under GHS ranking of hazards• A ranking of 1 means

the hazard is most severe in the hazard class

Very Important

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Pictograms

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OSHA specifies the use of only 8 pictograms

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OSHA specifies the use of these 8 pictograms

Appendix C

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Pictogram: Skull and Crossbones

• Acute Toxicity (severe)

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Pictogram: Corrosion

• Corrosives - A substance or a mixture that by chemical action will materially damage, or even destroy, metals is considered corrosive to metal. Skin corrosion means the production of irreversible damage to the skin.

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Pictogram: Health Hazard

• Carcinogen• Respiratory Sensitizer• Reproductive Toxicity• Target Organ Toxicity• Mutagenicity• Aspiration Toxicity

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Pictogram: Exclamation Mark

• Irritant -the production of reversible damage to the skin• Dermal Sensitizer – sensitization means that the repeated application

of the stimulus results in the progressive amplification of a response.• Acute Toxicity (Harmful) – the lowest hazard category of acute toxicity.• Narcotic Effects• Respiratory Tract Irritation – reversible damage to the respiratory tract

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Pictogram: Flame

• Flammables • Self Reactives – lower hazard than the exploding bomb,

but is a thermally unstable liquid or solid substance liable to undergo a strongly exothermic decomposition

• Pyrophorics• Organic Peroxides

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Pictogram: Exploding Bomb

• Explosives• Self reactive substances and mixtures - thermally

unstable substance liable to undergo a strongly exothermic decomposition

• Organic peroxides

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Pictogram: Flame over Circle

• Oxidizers – substances which, by providing oxygen, cause or contribute to the combustion of other material more than air does

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Pictogram: Gas Cylinder

• Gases Under Pressure

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Compare DOT and HCS Pictograms

Red border GHS------

Black border

Transport

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Signal Words, Hazard Statements and Precautionary Statements

Category see Appendices A & B, Signal Word, Hazard Statements and Precautionary Statements see Appendix C

Signal Word

A word used to indicate the relative severity of hazard on the label and SDS

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OSHA specifies the use of one of two possible Signal Words

• DangerThis signal word is used for the most severe hazard in each category. Example: Gasoline Flammability hazard indicates use of the signal word “Danger” due to Flash point < 73oF (Category 1)

• WarningThis signal word is used for less severe hazards in each category.Example: Acetic acid Flammability hazard indicates use of the signal word “Warning” due to Flash Point > 60oF and <140oF (Category 3)

Category see Appendices A & B, Signal Word see Appendix C

Hazard Statement

A statement assigned to a hazard class and category that describes the nature of the hazard

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Example: The Hazard Category and Signal Word are associated with a specific

Hazard Statement

• Gasoline:Hazard Category Flammable Liquid: 1Signal Word: Danger

Hazard Statement: Extremely flammable liquid and vapor

• Acetic Acid:Hazard Category Flammable Liquid: 3Signal Word: Warning

Hazard Statement: Flammable liquid and vapor

Appendix C

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Example: The Pictogram for these two materials is the same for this hazard

• Gasoline:Hazard Category Flammable Liquid: 1Signal Word: Danger

Hazard Statement: Extremely flammable liquid and vapor

• Acetic Acid:Hazard Category Flammable Liquid: 3Signal Word: Warning


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Multiple Pictograms and Hazard Statements may be required depending on the hazards, but only one Signal

word this is called the “precedence of hazard”

• Acetic Acid:Hazard Category Corrosive: 1Signal Word: Danger

Hazard Statement: Causes severe skin burns and eye damage

• Acetic Acid:Hazard Category Flammable Liquid: 3


When one hazard indicates the Signal word, “Danger”, it is the only Signal word used. However, all Hazard Statements and Hazard Categories will be listed.

Precautionary Statements

A phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from

• exposure, • improper storage or • handling of a hazardous

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There are four types of Precautionary Statements

1. Prevention – to minimize or prevent adverse effects

2. Response – what to do in the event of exposure

3. Storage – precautions for storing the materials

4. Disposal – specific instructions for disposal

Appendix C

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Example: Precautionary Statements are specific to the chemical

• Example: for Gasoline– Prevention “Keep away from heat/sparks/open

flames”– Response “Take off immediately all contaminated

clothing”– Storage “Store in a well-ventilated place. Keep

cool.”– Disposal - specific instructions for disposal

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Example: Precautionary Statements are specific to the chemical

• Example: for Acetic Acid– Prevention “Keep away from flames and hot

surfaces”– Response “In case of fire use … to extinguish”– Storage “Store in a well-ventilated place. Keep

cool.”– Disposal - specific instructions for disposal

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Quiz Yourself

• Are you sure of what each pictogram means ?• What information is conveyed by the

pictogram?• Is that the whole story?• How do NFPA and the new Category

numbering compare?

LabelsThe Label contents and to a certain

extent the format of the Label is specified in the new standard.

29 CFR 1910.1200(f) and Appendix C88Copyright ©2013

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Labels

• The Label contents and to a certain extent the format of the Label is specified in the new standard.

29 CFR 1910.1200(f) and Appendix C

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The Revised Standard requires that…

• Labels on “shipped containers” must contain the following elements– Product identifier– Signal Word– Hazard Statements– Pictograms– Precautionary Statements– Name, address, and phone number of the

manufacturer, importer or other responsible party29 CFR 1910.1200(f)(1)

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What is a “container”?

• (c)_ Container means any bag, barrel, bottle, box, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical (pipes or piping systems and engines, fuel tanks or other operating systems are not containers)

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The Revised Standard requires that…

• The Manufacturer shall ensure that the information – Signal Word– Hazard Statements– Pictograms

Is located “together” on the label

29 CFR 1910.1200(f)(3)

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Precedence of Hazard

• Not all hazards will be represented by their Pictogram and Signal Word– If “Danger” is included, “Warning “ shall not appear– If Skull and Crossbones is included, the Exclamation

Point shall not appear– If Corrosive is included, the Exclamation Point shall

not appear– If Health Hazard is included, the Exclamation Point

shall not appear where it is used for skin sensitization or skin / eye irritation

29 CFR 1910.1200 Appendix C, C.2.1

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Labels

• Three standardized label elements:– Symbols (Hazard Pictograms) that convey health,

physical, and environmental hazard information assigned to a GHS hazard class and category

– Signal Words “Danger” or “Warning” used to emphasize hazards and relative level of severity of the hazard and assigned to a GHS hazard class and category

– Hazard Statements which are standard phrases assigned to a hazard class and category that describe the nature of the hazard

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Labels Contents is Specified:

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Label elements must be in accordance with Appendix C

Pictograms

Signal Word

Hazard Statement


Supplier Information

Product Identifier

Solvent A

Pictogram (required) Pictogram Pictogram Pictogram Pictogram

Danger

May cause cancer. Extremely flammable liquid and vapor. Harmful if inhaled. Causes skin irritation.

Prevention: Obtain special instructions before use. Do not handle until all safety precautions have been

read and understood. Wear protective glove/ protective clothing/ eye protection/ face protection. Keep away from heat/sparks/open flames. No smoking. Avoid breathing vapors. Use only outdoors or in a

well-ventilated area. Wash thoroughly after handling.

Response: If exposed or concerned Get medical advice/ attention. If on skin: take off immediately all

contaminated clothing. Rinse skin with water/shower. In case of fire: Do not use solid stream of water, since stream will scatter and spread fire. Fine water spray can be used to keep fire-exposed containers

cool.. If inhaled: remove person to fresh air and keep comfortable for breathing. Call a doctor if you feel

unwell.

Storage: Store locked up. Store in a well-ventilated place. Keep cool.

Disposal: Dispose of contents/container ….

First Aid:

Supplier InformationPackage Information (Weight, Lot # , Fill Date, Expiration Date)

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Example: the label for Benzene might look like this

Pictograms

Signal Word

Hazard Statement



Product Identifier

Benzene


Danger


Prevention: Obtain special instructions before use. Do not handle until all safety precautions have been read and understood. Wear protective glove/ protective clothing/ eye protection/ face protection. Keep away from heat/sparks/open flames. No smoking. Avoid

breathing vapors. Use only outdoors or in a well-ventilated area. Wash thoroughly after handling.

Response: If exposed or concerned Get medical advice/ attention. If on skin: take off immediately all contaminated clothing. Rinse skin with water/shower. In case of fire: Do not use solid stream of water, since stream will scatter and spread fire. Fine water spray

can be used to keep fire-exposed containers cool.. If inhaled: remove person to fresh air and keep comfortable for breathing. Call a doctor if you feel unwell.



First Aid:


Copyright ©2013 98

Example: label for Acetic Acid might look like this

Pictograms

Signal Word

Hazard Statement



Product Identifier

Acetic Acid


Danger

Flammable liquid and vapor. Corrosive to skin.

Prevention: Keep away from heat/sparks/open flames. No smoking. Keep container tightly closed. Ground/ bond container and receiving equipment. Use only non-sparking tools. Wear protective gloves, eye protection, face protection.

Response: If on skin: take off immediately all contaminated clothing. Rinse skin with water/shower. In case of fire: Do not

use solid stream of water, since stream will scatter and spread fire. Fine water spray can be used to keep fire-exposed containers cool.

. If inhaled: remove person to fresh air and keep comfortable for breathing. Call a doctor if you feel unwell.

Storage: Store in a well-ventilated place. Keep cool.


First Aid:


Copyright ©2013 100

DOT Labels as required by 49 CFR will still be on containers when required

The revised HAZCOM standard says “where a pictogram required by the Department of Transportation under 49 CFR appears on a shipped container, the pictogram specified in the HAZCOM standard shall not appear” C.2.3.3

But …. (see next slide)


OSHA intends to clarify the OSHA GHS/DOT label confusion

From the OSHA website, Publication 3636: http://www.osha.gov/Publications/OSHA3636.pdf

“However, DOT does not view the HCS pictogram as a conflict and for some international trade both pictograms may needto be present on the label. Therefore, OSHA intends to revise C.2.3.3. In the meantime, the agency will allow both DOT and HCS pictograms for the same hazard on a label.While the DOT diamond label is required for all hazardous chemicals on the outside shipping containers, chemicals in smaller containers inside the larger shipped container do notrequire the DOT diamond but do require the OSHA pictograms.”

http://www.osha.gov/Publications/OSHA3636.pdf




NFPA Label for Benzene

HCS Label for Benzene might look like this

Benzene

Danger


Prevention: Obtain special instructions before use. Do not handle until all safety precautions have been read and understood. Wear protective glove/ protective

clothing/ eye protection/ face protection. Keep away from heat/sparks/open flames. No smoking. Avoid breathing vapors. Use only outdoors or in a well-ventilated area.

Wash thoroughly after handling.

Response: If exposed or concerned Get medical advice/ attention. If on skin: take off immediately all contaminated clothing. Rinse skin with water/shower. In case of fire: Do not use solid stream of water, since stream will scatter and spread fire. Fine water

spray can be used to keep fire-exposed containers cool.. If inhaled: remove person to fresh air and keep comfortable for breathing. Call a

doctor if you feel unwell.



First Aid:


The Category number is not required on the label, but will appear on the Safety Data Sheet


• Hazards not otherwise classified do not have to be addressed on the container. (f)(1)


Hazards Not Otherwise Classified(HNOC)

• HNOC hazards will not be required to be disclosed on the label but will be required to be disclosed in Section 2 of the Safety Data Sheet (SDS).

• Chemical manufacturers and importers are expected to assess these hazards when they are conducting their hazard evaluation of physical and health hazards.

• Also in the final standard, in response to comments, OSHA has removed pyrophoric gases, simple asphyxiants, and combustible dust from the HNOC hazard category and has addressed these chemicals individually in Appendix C.


Combustible Dust

• Combustible dust hazards must be addressed on labels and SDSs. Label elements are provided for combustible dust in the final Hazard Communication Standard and include the signal word “Warning" and the hazard statement "May form combustible dust concentrations in the air".

Appendix C, C.4.30


Combustible Dust formed under Normal Conditions of Use

• For chemicals in a solid form that do not present a combustible dust hazard, but may form combustible dusts while being processed in normal downstream uses, paragraph (f)(4) allows the chemical manufacturer some flexibility in labeling requirements. The manufacturer or importer may transmit the label to the customer at the time of the initial shipment, but the label does not need to be included with subsequent shipments unless it changes.


Combustible Dust

• The label and SDS provides the needed information to the downstream users on the potential hazards in the workplace, while acknowledging that the solid metal or other materials do not present the same hazards that are produced when these materials are processed under normal conditions of use.


Simple Asphyxiants

• Simple asphyxiants must be labeled where appropriate, and be addressed on the SDS.

• OSHA has provided label elements for simple asphyxiants which include the signal word “Warning" and the hazard statement “May displace oxygen and cause rapid suffocation."


(b)(5) Standard does not require labeling of the following

• Pesticides that are subject to FIFRA labeling• Or other substances subject to EPA labeling• Any food, food additive, color additive, drug,

cosmetic or medical or veterinary device or product that are subject to FDA regulations (see 21 CFR)

• Any distilled spirits (these are subject to BATF regulations)

• Consumer products• Agricultural or vegetable seed subject to USDA

29 CFR 1910.1200(b)(5)


The standard also doesn’t apply to…

• Hazardous wastes• Hazardous substance regulated under CERCLA• Tobacco or tobacco products• Wood or wood products• Articles• Food or alcoholic beverages intended for personal

consumption in the workplace• Drugs (therapeutic) or cosmetics in the workplace• Consumer products in the workplace• Nuisance particulates, ionizing an non-ionizing radiation and

biological hazards.

Copyright ©2013

More on Labeling

• The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers and which are intended only for the immediate use of the employee who performed the transfer.

112

29 CFR 1910.1200(f)(8)


• The employer shall not remove or deface existing labels

• Labels shall be legible and in English and prominently displayed on the container.

29 CFR 1910.1200(f)(9) and (10)


The SDS will consist of 16 sections

1. Identification: GHS Product identifiers, recommended use and restrictions, supplier’s contact information and emergency phone number 2. Hazard Identification: GHS classification of the substance/ mixture as well as GHS label elements such as: signal words, hazard statements, precautionary statements, pictograms and any other hazards that may exist.

This is new


The SDS will consist of 16 sections3. Composition/Information on Ingredients: Information on the substance/mixture including chemical identity, impurities and stabilizing additives, and, in the case of mixtures, concentration of ingredients. (No <1% exemption)4. First-aid Measures: Description of necessary first-aid according to routes of exposure, most important symptoms/effects and indication of immediate medical attention and special treatment 5. Fire-Fighting Measures: Details about suitable extinguishing media, hazards arising from the chemical (e.g. combustion), protective equipment and precautions for firefighters .


6. Accidental Release Measures: PPE for use in an emergency, emergency procedures, environmental precautions as well as methods and materials for containment and cleaning up. 7. Handling and Storage: Description of precautions for safe handling and conditions for safe storage, including any incompatibilities. 8. Exposure/Controls/Personal Protection: Appropriate engineering controls, OSHA permissible exposure limit (PEL) and personal protective equipment.

All of these sections you have seen on MSDS:


6. Accidental Release Measures: PPE for use in an emergency, emergency procedures, environmental precautions as well as methods and materials for containment and cleaning up. 7. Handling and Storage: Description of precautions for safe handling and conditions for safe storage, including any incompatibilities. 8. Exposure/Controls/Personal Protection: Appropriate engineering controls, OSHA permissible exposure limit (PEL) and personal protective equipment.



9. Physical and Chemical Properties: Description of chemical appearance (physical state, color etc.), odor and physical / chemical properties (e.g. pH, melting point/freezing point, initial boiling point/range, flash point, UEL, LEL, specific gravity or density, vapor pressure) 10. Stability and Chemical Properties: Information regarding chemical stability, possible hazardous reactions, incompatible materials, hazardous decomposition products and conditions to avoid (e.g. static discharge, shock or vibration). 11. Toxicological Information: Concise, complete and comprehensible description of the health effects and the available data used to identify those effects (e.g. routes of exposure, symptoms, delayed and immediate effects from exposure and numerical measures of toxicity).



12. Ecological Information: Information about the Eco toxicity, persistence and degradability, bio accumulative potential, mobility in soil and other adverse effects. 13. Disposal Considerations: Description of waste residues and information on their safe handling and methods of disposal, including the disposal of any containment packaging.14. Transport Information: Includes information such as UN number, proper shipping name, transport hazard class(es), packing group, whether chemical is a marine pollutant, and any territory specific special precautions

Sections 12-15 are not required by OSHA, but the information may be required by EPA and DOT standards.


15. Regulatory Information: Safety, health and environmental regulations specific for the product in question. 16. Other Information: For every chemical found to be hazardous, the chemical manufacturer or importer must develop a container label and an SDS and provide both documents to downstream users of the chemical. All employers with employees exposed to hazardous chemicals must develop a hazard communication program, and ensure that exposed employees are provided with labels, access to SDS, and training on the hazardous chemicals in their workplace.

Sections 12-15 are not required by OSHA, but the information may be required by EPA and DOT standards.


16. Other Information: This section must include the date of preparation of the SDS or the last revision date.

If no relevant information is found for any given subheading within a required section, the SDS shall clearly indicate that no applicable information is available.

Section 16 is Required:


Does the SDS just address the hazards that exist? Or also potential hazards?

• Yes – hazards that exist with the product as shipped• And yes – hazards that might exist as a result of

handling and use, example: dust that might be generated in handling, or hazards of handling such as thermal burns from product that is heated for processing.– Appendix D, Table D-1 (c) Describe any hazards not

otherwise classified that have been identified during the classification process


Does the Classification and Categorization cover all the

possibilities of hazard?

• Appendix D, Table D-1– (c) Describe any hazards not otherwise classified

that have been identified during the classification process


Summary• New Labels and SDS will start to appear in the workplace• Pictograms are intended to denote the type of hazard, not the

severity• Signal word “Danger” indicates more severe hazard than

“Warning”• Hazard within a class is ranked, with Category 1 being the

most severe hazard within the class. This is opposite to HMIS and NFPA ranking of hazards (0 or 1 is no hazard, 4 is most severe). NFPA and HMIS labels do not have to be removed, but the new labels must be affixed.

• If a container has a DOT label, it does not need the new label.• First compliance date is 12/1/2013: All employees must be

trained in the new GHS system of SDS and Labeling


Compliance DatesEffective

Completion Date

Requirement(s) Who

December 1, 2013

Train employees on label elements and SDS format. Employers

June 1, 2015*

December 1, 2015

Comply with all modified provisions of this final rule, except:- Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.

Chemical manufacturers, importers, distributors and employers

June 1, 2016Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

Employers

Transition Period

Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both.

All chemical manufacturers, importers, distributors and employers

29 CFR 1910.1200(j)


Review

• If you use MSDS:– Now called SDS– Difference between NFPA and new Hazard

numbering– Pictograms – interpretation– Signal words – definitions– Must train employees by 12/1/2013


Review

• If you prepare MSDS:– They are now called SDS– Complicated hazard classification required– Hazard numbering system required– Pictograms – required– Signal words – required– Compliance date in 2015


Quiz

1. What is the first compliance date for the new Hazcom Standard?

2. Is a written Hazcom program required?3. Can you or should you put both the DOT

required label and the new HCS label on the same drum?

4. Can you put the NFPA label and new HCS label on the same container?

5. What is the new name for the MSDS?


Quiz continued

6. How are NFPA numbering and Hazcom Category numbering different?

7. When do you have to train (frequency)?8. What is the compliance date for complete

compliance?9. What is the pictogram for acute toxicity? 10. What is the pictogram for target organ

effects?


Quiz

1. What is the first compliance date for the new Hazcom Standard? 12/1/2013, training of employees

2. Is a written Hazcom program required? Yes3. Can you or should you put both the DOT required

label and the new HCS label on the same drum? If a DOT label is required, do not put a new HCS label on the container, however this may change.

4. Can you put the NFPA label and new HCS label on the same container? Yes

5. What is the new name for the MSDS? SDS


Quiz continued

6. How are NFPA numbering and Hazcom Category numbering different? With NFPA, a larger number is the greater hazard, with HCS, it is the opposite.

8. What is the compliance date for complete compliance? 6/1/2016

9. What is the pictogram for acute toxicity? 10.What is the pictogram for target organ

effects?


Links

• http://www.osha.gov/Publications/OSHA3514.html OSHA Brief on SDS

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

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

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

http://www.osha.gov/Publications/OSHA3514.html

http://www.osha.gov/Publications/OSHA3514.html

http://www.osha.gov/Publications/HazComm_QuickCard_SafetyData.html



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



http://www.osha.gov/Publications/HazComm_QuickCard_Pictogram.html




Links

• http://www.osha.gov/dsg/hazcom/index2.html

• http://www.osha.gov/dsg/hazcom/hazcom-faq.html#12

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

http://www.osha.gov/dsg/hazcom/index2.html

http://www.osha.gov/dsg/hazcom/index2.html

http://www.osha.gov/dsg/hazcom/hazcom-faq.html#12



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




The End

the revised hazard communication standard 29 cfr 1910.1200 final rule march 26, 2012 safety data...

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