OSHA 1910.1200 StandardSeveral states enacted their own ―Right to Know‖ lawChemical manufacturers wanted one uniform law vs. various state laws1910.1200 Ordered by Congress -1985Global Harmonization Standard (GHS) added in 2012
PurposeTo ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards are transmitted to employers and employees.Accomplished with:- container labeling- material safety data sheets- employee training
Outline of Standard(a) Purpose(b) Scope(c) Definitions(d) Hazard Classification(e) Written Hazard Communication Program(f) Labels and Other Forms of Warning(g) Safety Data Sheets(h) Employee Information and Training(i) Trade Secrets(j) Effective Dates(k) Other Standards Affected(l) Appendices
Definitions Terms no longer being defined due to changes in terminology: Hazard warning; identity; and material safety data sheet (MSDS) Terms revised to be consistent with the GHS: Chemical; chemical name; hazardous chemical; health hazard; label; mixture; physical hazard; and trade secret
DefinitionsThe following terms are being added to the definitions section: Classification; hazard category; hazard class; hazard not otherwise classified; hazard statement; label elements; pictogram; precautionary statement; product identifier; pyrophoric gas; safety data sheet (SDS); signal word; simple asphyxiant; and substance These terms are primarily related to the changes in approach to evaluating hazards, and providing label information
Definitions“Chemical”OSHA previously used ―chemical‖ to indicate both substances and mixturesOSHA has decided to continue using ―chemical‖ in the final rule as meaning those situations where both substances and mixtures are being addressed―Hazardous chemical‖ means 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
Definitions“Hazards Not Otherwise Classified”Classified identifies a hazard, but the evidence does not meet the currently specified criteria covered by Haz Com 2012Example: Static Accumulator, Magnetic, etc.Information will be required on the safety data sheets in Section 2Hazard information on the label, is not mandatory, but can be provided under supplementary informationSuch hazards must also be addressed in worker training
Definitions“Precautionary statement” means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling. For example: Wear face protection [for Explosives, Division 1.1]
(d) Hazard Classification Each type of hazard covered is considered a ―hazard class‖—such as acute toxicity, carcinogenicity However, most of these hazard classes are also sub- divided into ―hazard categories‖ to reflect the degree of severity of the effect This is the concept of ―classification‖—rather than just determining that there is a hazardous effect (carcinogenicity), there is also a finding of how severe that effect might be (Category 1 or 2)
(d) Hazard ClassificationClassification ProvisionsChemical manufacturers and importers must classify each chemical they produce or import: Determine the appropriate hazard classes and associated hazard categories Base this on an evaluation of the full range of available data/evidence on the chemical (no testing is required) Use Appendix A for health hazard criteria and Appendix B for physical hazard criteria The introduction to Appendix A provides the general approach to classification, including bridging principles
Physical HazardsHazard Class Hazard CategoryExplosives Unstable Div 1.1 Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6 ExplosivesFlammable Gases 1 2Flammable Aerosols 1 2Oxidizing Gases 1Gases under Pressure 1 Compressed Gases Liquefied Gases Refrigerated Liquefied Gases Dissolved GasesFlammable Liquids 1 2 3 4Self-Reactive Chemicals Type A Type B Type C Type D Type E Type F Type GPyrophoric Liquids 1Pyrophoric Solid 1Pyrophoric Gases Single categorySelf-heating Chemicals 1 2Chemicals, which in 1 2 3contact with water, emitflammable gasesOxidizing Liquids 1 2 3Oxidizing Solids 1 2 3Organic Peroxides Type A Type B Type C Type D Type E Type F Type GCorrosive to Metals 1Combustible Dusts Single Category
(e) Program RequirementsWritten programList of all hazardous chemicalsAddresses non-routine tasksDiscusses other contractors responsibilitiesAvailable upon request to any employee or contractor
(e) Written ProgramDescribes how the standard will be implemented in that facilityContains a list of all chemicals
(f) Labels Required Elements Product identifier Signal words Hazard statements Pictograms Precautionary statements Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party A new Appendix C, Allocation of Label Elements, has been provided to indicate the label requirements by hazard class and category Labels are to be updated within 6 months of getting new and significant information about the hazards, or ways to protect those exposed
(f) Labels OSHA is maintaining the current approach to allowing alternatives to labels on each stationary process container The exception for portable containers under the control of the person who filled them with the chemical remains the same. Labels on incoming containers are not to be removed or defaced unless immediately replaced by another label Workplace labels are to be prominently displayed and in English, although other languages are permitted as well
(f) Labels Example
(f) Labels Sample HS85 Label HS85 Warning Batch number: 85L6543 Harmful if swallowed. Wash hands and face thoroughly after handling. Do not eat, drink or smoke when using this product. Dispose of contents/container in accordance with local, state and federal regulations. First aid: If swallowed: Call a doctor if you feel unwell. Rinse mouth. GHS Example Company, 123 Global Circle, Anyville, NY 130XX Emergency Telephone (888) 888-8888
(f) LabelsEmployers are responsible for maintaining the labels on the containers, including, but not limited to, tanks, totes, drums, and for training their employees on the hazards listed on the labels in the workplace.Labels must continue to be: legible contain the pertinent information (such as the hazards and directions for use) not able to be defaced, (i.e., fade, get washed off,) or removed in any way as stated in revised Hazard Communication Standard, 29 CFR 1910.1200(f)(9)
(g) Safety Data Sheets (SDS) The GHS uses a specified order of information, as well as title descriptions, on the 16-section safety data sheet. Health, physical and environmental hazard criteria for substances and for classification of mixtures. Consistent with voluntary industry consensus standards, such as ANSI. Should improve comprehensibility and issues regarding accuracy of information.
(g) Safety Data Sheet Format1. Identification of the 9. Physical and chemical substance or mixture and properties of the supplier 10. Stability and reactivity2. Hazards identification 11. Toxicological information3. Composition/information 12. Ecological information on ingredients (non-mandatory)4. First-aid measures 13. Disposal considerations5. Fire-fighting measures (non-mandatory)6. Accidental release 14. Transport information measures (non-mandatory)7. Handling and storage 15. Regulatory information8. Exposure (non-mandatory) controls/personal 16. Other information, including protection date of preparation or last revision
(g) Safety Data Sheets (SDS)SDS in the workplace for each hazardous chemical which is usedOSHA requires these forms for each hazardous chemicalsReadily accessible during each work shift to employees when they are in their work area(s)
(g) Safety Data Sheets (SDS)Identifies chemicals by nameTells potential harm and how chemicals will enter the body (Inhalation, ingestion, and/or skin absorption)Explains signs and symptoms of exposuresExplains emergency procedures
(h) Employee Training Although this paragraph remains essentially the same, updates include Training to include label elements and new safety data sheet format - by December 1, 2013 Training to reflect any new hazards identified in the workplace - by June 1, 2016 Training – prescribed label elements and order of information on data sheets facilitate training/comprehensibility.
(h) Employee TrainingTrained initially and when new chemical Location of program, introduced list of chemical, andOSHA standard SDS covered Detection of chemicalOperations in their Hazards of chemical work area where Protection measures chemical is used EmergencyPictograms procedures Labeling system used
Temporary Employees The temporary agency employer would provide generic hazard training and information concerning categories of chemicals employees may potentially encounter Host employers would then be responsible for providing site- specific hazard training pursuant to sections 1910.1200(h)(1)
Compliance IssuesCan employees retrieve information stored on a computer?How do employees speaking other language understand labels in English?Who puts labels on portable containers?
More IssuesHow is the outside contractor informed of chemicals in the area?What do you do if the label falls off an old container?How is chemical piping labeled?What chemicals do I have that may contain cancer causing chemicals?
Appendices Appendix A, Health Hazard Criteria (Mandatory) (NEW) Appendix B, Physical Hazard Criteria (Mandatory) (NEW) Appendix C, Allocation of Label Elements (Mandatory) (NEW) Appendix D, Safety Data Sheets (Mandatory) (NEW) Appendix E, Definition of ―Trade Secret‖ (Mandatory) Appendix F, Guidance for Hazard Classifications re: Carcinogenicity (Non-Mandatory) (NEW)
FLAMMABLE LIQUIDS (Classified in Accordance with Appendix B.6) Pictogram Flame Hazard Signal Hazard statementcategory word 1 Danger Extremely flammable liquid and vapor 2 Danger Highly flammable liquid and vapor 3 Warning Flammable liquid and vapor Pictogram No Pictogram Hazard Signal Hazard statementcategory word 4 Warning Combustible liquid
Revision of 29 CFR 1910.106Flammable LiquidsFlammable liquids are divided into four categories as follows:(i) Category 1 . . . FPs below 73.4 o F (23 o C) and having a BP at or below 95 o F (35 o C).(ii) Category 2 . . . FPs below 73.4 o F (23 o C) and BP above 95 o F (35 o C).(iii) Category 3 . . . FPs at or above 73.4 o F (23 o C) and at or below 140 o F (60 o C).(iv) Category 4 . . . FPs above 140 o F (60 o C) and at or below 199.4 o F (93 o C).
Revision of 29 CFR 1910.106Flammable Liquids GHS Flammable and Combustible Liquids Standard (29 CFR 1910.106) Category Flashpoint ºC ( F) Boiling Class Flashpoint ºC ( F) Boiling Point Point ºC ( F) ºC ( F)Flammable 1 < 23 (73.4) ≤ 35 (95) Flammable Class IA < 22.8 (73) < 37.8 (100)Flammable 2 < 23 (73.4) > 35 (95) Flammable Class IB < 22.8 (73) ≥ 37.8 (100)Flammable 3 ≥ 23 (73.4) and ≤ Flammable Class IC ≥ 22.8 (73) and < 37.8 60 (140) Combustible Class II (100) ≥ 37.8 (100) and < 60 (140)Flammable 4 > 60 (140) and ≤93 Combustible Class IIIA ≥ 60 (140) and <93.3 (199.4) (200)None Combustible Class IIIB ≥ 93.3 (200) ** Not covered by §1910.1200 or §1910.106 however interpretation letter indicates these are covered by §1910.107
Safety StandardsFlammable Liquids 1910.106HCS 1994 Flame arresters or venting devices required in subdivision (f) of this subdivision may be omitted for Class IB and IC liquids where conditions are such that their use may, in case of obstruction, result in tank damage.HCS 2012 (g) Flame arresters or venting devices required in paragraph (B)(2)(iv)(f) of this section may be omitted for Category 2 flammable liquids and Category 3 flammable liquids with a flashpoint below 100 °F (37.8 °C) where conditions are such that their use may, in case of obstruction, result in tank damage.
Safety StandardsPSM 1910.119(a)(1)(ii)HCS 1994 A process which involves a flammable liquid or gas (as defined in 1910.1200(c) of this part) on site in one location, in a quantity of 10,000 pounds (4535.9 kg).HCS 2012 A process which involves a Category 1 flammable gas (as defined in 1910.1200 (c)) or a flammable liquid with a flashpoint below 100 °F (37.8 °C) on site in one location, in a quantity of 10,000 pounds (4535.9 kg)
(j) Effective Dates Requirements) WhoEffective Completion DateDecember 1, 2013 Train employees on the new label Employers elements and safety data sheet (SDS) format.June 1, 2015* Compliance with all modified Chemical manufacturers, importers,December 1, 2015 provisions of this final rule, except: distributors and employers The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS labelJune 1, 2016 Update alternative workplace labeling Employers and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.Transition Period to the effective May comply with either 29 CFR Chemical manufacturers, importers,completion dates noted above 1910.1200 (the final standard), or the distributors, and employers current standard, or both
Quiz1) The Pictogram in the upper right is for _____.2) Training in the hazards of the chemical is initially and when __________________.3) _______ use containers would not require a label.4) Name at least two things an employee would have to be trained on for flammable paint: ________________ ___________________5) SDS’s must be accessible to employees during their _____________________________.6) Name two chemicals that would be in the list of hazardous chemicals? ___________ ______________
312-353-5977 Facebook….john newquist firstname.lastname@example.org Twitter is johnanewquistNewquist.email@example.com LinkedIn is john newquist
Further This was prepared as a collaborative effort several friends as a preliminary aid for anyone in the safety and health field. These are just some the issues. A comprehensive job hazard analysis should be conducted for any task where someone can get hurt. This is not an official OSHA publication. Those will be on the OSHA.gov website. If you see any errors my email is Newquist.firstname.lastname@example.org 312-353-5977 I want to thank Paul Satti, Joe H. Matt S. and Janet S. for all their assistance in answering questions and providing insight to the many hazards in this sector. Deana Holmes, Kathy Landkrohn, Jennifer Lawless, and Maureen Ruskin conducted a webinar on this subject for OSHA and their PowerPoint was a basis of this one.