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Hazcom GHS Compliance Guide

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Hazcom GHS Compliance Guide

Hazcom GHS Compliance Guide

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  • In addition, the following terms are not being defined in because they are no longer needed due to changes in terminology: Hazard warning; identity; and material safety data sheet (MSDS). Regarding material safety data sheet, this term was removed, but is replaced by the new term safety data sheet. The definitions for the following terms are being revised to be consistent with the GHS and, ultimately, Haz Com 2012: Chemical; chemical name; hazardous chemical; health hazard; label; mixture; physical hazard; and trade secret
  • Most of the terms added to the definitions paragraph of Haz Com 2012 are related to evaluating hazards and proper label information.For example – classification requires manufacturers, importers, and distributors to evaluate the hazards of the chemicals they produce, and select the appropriate hazard class and hazard category, using the criteria provided in Appendices A and B. As Deana will discuss in a little bit, the classification approach is different than the determination approach used in Haz Com 1994.You’ll notice that pyrophoric gas and simple asphyxiant are listed as definitions added to this paragraph of the rule. These hazards were included in Haz Com 1994, but are not included in the GHS. OSHA added these hazard definitions to Haz Com 2012 so that the rule would maintain its existing hazard coverage.
  • OSHA previously used “chemical” to indicate both substances and mixtures. We will continue to use this term in the same manner. Similarly, the term “hazardous chemical” will also be used as a shorthand reference to both substances and mixtures after they have been classified as hazardous or determined to be a hazard not otherwise classified.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.
  • Information on hazards not otherwise classified is required to be provided in Section 2 of the safety data sheet. That’s the Hazard Identification section of the safety data sheet.However, information for hazards not otherwise classified is not required on the label, but it can be provided as supplemental information. Of course, if such a hazard is identified, it must be included in worker training.What's an example of a hazards not otherwise classified?? Static accumulatorThe definition for hazards not otherwise classified is intended to address situations where a classifier has identified evidence of a hazard during the normal classification process, but the evidence does not meet the currently specified criteria for hazards covered by Haz Com 2012. The definition for hazards not otherwise classified captures those effects to ensure that Haz Com 2012 is appropriately protective, and covers all of the hazards covered by Haz Com 1994. You see, Haz Com 1994 was an umbrella standard, designed to capture chemical hazards in the workplace, even those that had not been identified at the time the rule was promulgated. By including a definition for hazards not otherwise classified, we are maintaining this coverage.
  • Precautionary statements describe recommended measures that should be taken to protect against hazardous exposures, or improper storage or handling of a chemical.
  • This paragraph requires that chemical manufacturers and importers identify and evaluate the available scientific evidence on a chemical to determine if it is hazardous, as well as determine the degree of hazard using the criteria for health and physical hazards located in Appendices A and B.Hazard classification provides the basis for the hazard information that is provided on labels, SDSs, and in employee training. Therefore, it is important that classification be performed accurately and consistently. Each type of hazard covered is considered a “hazard class”—such as acute toxicity or carcinogenicityAnd most of these hazard classes are also sub-divided into “hazard categories” to reflect the degree of severity of the effect (for instance- category 1, or category 3)The general concept of classification is to determine the hazardous effect (such as carcinogenicity) and the severity of the effect (such as category 1 or category 2)
  • This slide provides the major steps in hazard classification:Chemical manufacturers and importers must classify each chemical they produce or import:Determine the appropriate hazard classes and associated hazard categoriesBase 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 criteriaThe introduction to Appendix A provides the general approach to classification, including bridging principles ( which is the approach used to determine classification of mixtures)
  • This table shows the hazard classes and categories OSHA adopted in its final rule.As with health hazards, OSHA tried to maintain the scope of Haz Com 1994 for physical hazards in Haz Com 2012. Therefore, you will notice this list also includes pyrophoric gases and combustible dusts. The definition for pyrophoric gas is contained in paragraph (c) and the label elements are presented in Appendix C.For combustible dust, we are treating as we always have. The definition for this hazard is provided in the Combustible Dust NEP (Directive CPL 03-000-008). Guidance on this hazard is provided using existing documents, including those on OSHA’s webpage. In addition there are a number of voluntary consensus standards (particularly those from NFPA) that address combustible dust.Deana will now talk about the hazard communication program and labels.
  • Hazcom 2012 requires that labels on shipped containers contain much more information than required by Hazcom 1994, such as: the product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party. However, much of this additional information is already included on labels by manufacturers, particularly for those following the ANSI standard Z129 for precautionary labeling.  These elements are intended to be the minimum information to be provided on labels by manufacturers and importers.  So, if chemical manufacturers and importers want to provide additional information regarding the hazards of a chemical as well as precautions for safe handling and use, they are free to do so as long as the information is accurate, and does not conflict with the required label elementsAll of the label requirements by hazard class and category can be found in Appendix C
  • This slide lists the section headings of the SDS. To be consistent with the GHS, the revised standard requires that Sections 12 through 15 be listed on the SDS. We will not be enforcing the content of these sections since much of this information is not regulated by OSHA.We have provided Appendix D as a separate file for your reference – it contains all the requirements of each section of the safety data sheet.
  • The Appendices of Haz Com 2012 are listed on these slides. As Maureen mentioned earlier, the bulk of the technical requirements are provided in the Appendices. The reason OSHA did this was to make it easier for those people classifying chemicals, and creating labels and safety data sheets to find the information they need in one location rather than having it discussed throughout the regulatory text. Chemical users may not refer to this information as much as chemical producers. To produce useful appendices for Haz Com 2012, OSHA removed appendices from Haz Com 1994 that no longer applied and replaced them with updated information. Appendix A and B are new appendices and contain the definitions and classification criteria for the health and physical hazards, respectively.Appendix C is also new and contains the required label information for each hazard class.New Appendix D lists the safety data sheet sections and the requirements for the contents of each section.Appendix E is not new. The appendix has been re-numbered as it contains the Trade Secret information that used to be provided in Appendix D of Haz Com 1994.Appendix F is a new non-mandatory appendix that provides guidance to classifiers addressing carcinogenicity.
  • In the final rule OSHA decided not to phase in compliance based on whether a product is a substance or a mixture. OSHA concluded that adequate information is available for classifiers to use to classify substances and mixtures.Therefore, under the revised standard, covered employers must complete all training regarding the new label elements and SDS format by December 1, 2013 since, employees will begin seeing the new style labels considerably earlier than the compliance date for labeling. All other provisions to be in effect by June 1, 2015, except: Distributors who are passing on manufacturer labels to customers shall ensure all labels are updated by December 1, 2015 ( these distributors have an extra six months) IF distributors are not passing along manufacturer labels they MUST comply with the June 1, 2015 date for labels.Employers will also be given an additional year (by June 1, 2016) to update their hazard communication programs or any other workplace signs, if applicable.You may be curious about, or get asked “Why did OSHA pick June 1, 2015 for an effective date for labels?” This is because it coincides with the EU date for classifying mixtures.

Hazcom GHS Compliance Guide Hazcom GHS Compliance Guide Presentation Transcript

  • Hazard CommunicationFacts About GHS Compliance April - 2012
  • OSHA 1910.1200 StandardSeveral states enacted their own ―Right to Know‖ lawChemical manufacturers wanted one uniform law vs. various state laws1910.1200 Ordered by Congress -1985Global Harmonization Standard (GHS) added in 2012
  • OverviewPurposeDefinitionsGHS ChangesPictograms View slide
  • PurposeTo 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 View slide
  • 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
  • Health Hazards Classifications Hazard Class Hazard Category Acute Toxicity 1 2 3 4 Skin Corrosion/Irritation 1A 1B 1C 2 Serious Eye Damage/ Eye 1 2A 2B Irritation Respiratory or Skin Sensitization 1 Germ Cell Mutagenicity 1A 1B 2 Carcinogenicity 1A 1B 2 Reproductive Toxicity 1A 1B 2 Lactation STOT – Single Exposure 1 2 3 STOT – Repeated Exposure 1 2 Aspiration 1 Simple Asphyxiants Single Category
  • 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 RequirementsWritten programList of all hazardous chemicalsAddresses non-routine tasksDiscusses other contractors responsibilitiesAvailable upon request to any employee or contractor
  • (e) Written ProgramDescribes how the standard will be implemented in that facilityContains 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
  • Pictograms
  • (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 usedOSHA requires these forms for each hazardous chemicalsReadily accessible during each work shift to employees when they are in their work area(s)
  • (g) Safety Data Sheets (SDS)Identifies chemicals by nameTells potential harm and how chemicals will enter the body (Inhalation, ingestion, and/or skin absorption)Explains signs and symptoms of exposuresExplains 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 TrainingTrained initially and when new chemical Location of program, introduced list of chemical, andOSHA standard SDS covered Detection of chemicalOperations in their Hazards of chemical work area where Protection measures chemical is used EmergencyPictograms 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 IssuesCan employees retrieve information stored on a computer?How do employees speaking other language understand labels in English?Who puts labels on portable containers?
  • More IssuesHow 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? ___________ ______________
  • 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.john@dol.gov 312-353-5977 I want to thank Paul Saati, 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.