Under both the current Hazard Communication Standard (HCS) and the revised HCS, an evaluation of chemical hazards must be performed considering the available scientific evidence concerning such hazards. Under the current HCS, the hazard determination provisions have definitions of hazard and the evaluator determines whether or not the data on a chemical meet those definitions. It is a performance-oriented approach that provides parameters for the evaluation, but not specific, detailed criteria. The hazard classification approach in the revised HCS is quite different. The revised HCS has specific criteria for each health and physical hazard, along with detailed instructions for hazard evaluation and determinations as to whether mixtures or substances are covered. It also establishes both hazard classes and hazard categories—for most of the effects; the classes are divided into categories that reflect the relative severity of the effect. The current HCS does not include categories for most of the health hazards covered, so this new approach provides additional information that can be related to the appropriate response to address the hazard. OSHA has included the general provisions for hazard classification in paragraph (d) of the revised rule, and added extensive appendixes (Appendixes A and B) that address the criteria for each health or physical effect.
Old system – Label preparer must provide the identity of the chemical (what it is) and appropriate hazard warnings (what it does).New GHS – Hazard classification will generate label requirements specific for each hazard class and category.
Sections 1 through 8 contain general information that should be helpful to those who need to get the information quickly. Sections 9 through 16 contains other scientific and technical information.
Technical updates for minor terminology changes,Direct Final Rules for text clarification, andNotice and Comment rulemaking for more substantive or controversial updates such as additional criteria or changes in health or safety hazard classes or categories.
GHS Embraced by OSHA for 2013
How to Get Ready Now
Office: (303) 228-8753
KPA Product Manager
Office: (303) 228-2397
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What do you need to do?
Why Change HazCom?
Reduce chemical exposures
Prevent injuries, illnesses, and fatalities
Save money through productivity improvements
– Standardized SDS
– Easier international trade
– Simplified training
– Cost of implementing new HazCom = $201M/yr
– Reduction in injuries and fatalities = $250M/yr
– Productivity improvements = $750M/yr
– Total benefits = $1B/yr
Hazard Communication Standard: Current
– Hazard determination
Hazard Communication Standard: What’s New
– Hazard classification
Hazard Classification Changes
– Hazards are loosely defined
– No specific, detailed criteria
– Potential for ambiguity
– Specific criteria for physical and health hazards
– Detailed instructions for hazard evaluation
– Establishes hazard classes and hazard categories
Label: Required Elements
“Danger”>”Warning” Acute Toxicity - Oral
Label: Required Elements
Harmful if swallowed
Acute Toxicity - Oral
Label: Required Elements
Wash … thoroughly after handling.…
Chemical manufacturer, importer, or
distributor to specify parts of the body to
be washed after handling.
Do not eat, drink or smoke when using
If swallowed: Immediately call a poison
manufacturer, importer, or distributor to
specify the appropriate source of
emergency medical advice.
Specific treatment (see ... on this label)
... Reference to supplemental first aid
- if immediate administration of antidote is
Store locked up.
Dispose of contents/container to...
... in accordance with
regulations (to be specified).
Precautionary statements Acute Toxicity - Oral
Workplace Labels (Secondary Containers)
You have a choice:
– Use the Shipping Label, or;
– Label that provides words, pictures, symbols that:
• Provide “general information”
• Lead to specific information about the hazard
Section 1. Identification Section 9. Physical and chemical properties
Section 2. Hazard(s) identification Section 10. Stability and reactivity
Section 3. Composition/ingredients Section 11. Toxicological information
Section 4. First-aid measures Section 12. Ecological information*
Section 5. Fire-fighting measures Section 13. Disposal considerations*
Section 6. Accidental release measures Section 14. Transport information*
Section 7. Handling and storage Section 15. Regulatory information*
Section 8. Exposure controls and PPE Section 16. Other information, revision date
Material Safety Data Sheet Changes
Standard 16-Section Format
GHS is UN document with 2-year revision cycle
“further updates of HCS may be necessary”
• Technical updates
• Direct Final Rules
• Notice and Comment rulemaking
What Can you do: Now
• Talk to subcontractors who have chemicals
• Talk to vendors about updated labeling
• Update Chemical Inventory
• Chemical Spring Cleaning
• Start gathering new SDSs
• Update Training Programs
• Update Written Programs
We’re here to help!
By December 1, 2013
Train employees on GHS labels and SDS.
By June 1, 2016
Full compliance with GHS.
• Updated Labeling
• Written Programs