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 Hazard Communication Training Program by MIOSHA
 

Hazard Communication Training Program by MIOSHA

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  • Last revised: 08/23/13 – Jenelle’s updates <br /> This training session is designed to provide information to employees who work with hazardous chemicals and substances. Employers are required to provide training to employees by December 1, 2013. <br /> 08/16/13: Minor revisions were made associated with the compliance dates listed in the speakers notes on a few slides. <br />
  • This training includes: <br /> An overview of the changes to the MIOSHA Haz Com Standard; <br /> The new labeling requirements; <br /> Information on the new safety data sheets in the 16 section format; and, <br /> Details of the facility specific haz com program. This portion of the training program is designed to provide guidance to employers on information they must include in order for the employee training program to be compliant with the MIOSHA Haz Com Standard. <br />
  • So, why the change? <br /> Since 1992, the United Nations have been working to create and enhance a globally harmonized system for the classification and labeling of chemicals that can be used by importers, distributers and manufacturers worldwide. <br /> 2012 Haz Com revised standard is based on GHS revision 3. <br /> The goal is to provide a common and coherent approach to classifying chemicals. <br /> This will benefit employees as it will: <br /> Reduce confusion and increase understanding of the hazards. <br /> Facilitate training <br /> Help address literacy problems particularly due to use of pictograms <br />
  • This slide lists the other MIOSHA standards that are affected by the changes adopted in the 2012 Haz Com. <br /> Language on required signs in the listed standards, will be harmonized with Haz Com and GHS. <br /> For example the sign for lead will be changed as noted above. <br /> Chromium (VI) does not appear to have any changes. <br /> Refer to the signage handout (CET-5533) or the GHS page on the MIOSHA website, for additional information on signage requirements. <br /> http://www.michigan.gov/documents/lara/lara_miosha_cet5533_402987_7.docx <br /> Note: Label requirements for substance specific standards must be completed on or by June 1, 2015. <br /> Example: Asbestos pipe wrap (thermal system insulation) label must have be new language and placed by June 1, 2015, but the sign for the regulated area (area under abatement) must be updated by June 1, 2016. <br />
  • Here is a list of the other standards affected. <br /> In some cases, definitions may have changed in the standards listed above. <br /> Chromium (VI) does not appear to have any changes. <br /> Refer to the handout CET-5532 or the GHS page on the MIOSHA website, for additional information on the other Standards affected: <br /> http://www.michigan.gov/documents/lara/lara_miosha_cet5532_402986_7.doc <br />
  • This chart was provided by Federal OSHA with one addition which is noted in brackets. <br /> Effective on or by June 1, 2015:- All SDS must be completed and shipped/sent to users with the 1st order shipped on or after June 1, 2015. <br /> Employers/users of chemicals review to ensure all SDS received on or after June 1, 2015 are in the new format. <br /> Per OSHA, employers are not required to pursue getting new SDSs for products received before June 1, 2015; unless they are aware of changes to the hazards in the product. For older products, material safety data sheets for the products must kept as long as chemical is onsite/use,d then archived as required. <br /> - Vertical chemical specific standards with label requirements must be changed to harmonize with 1910.1200 Haz Com. <br /> Effective on or by June 1, 2016 <br /> - Employer/user must have program updated including any additional training and any label changes completed. <br /> - Vertical chemical specific standards with signage requirements will be changing to harmonize with 1910.1200 Haz Com. The added text in brackets reflects this. <br />
  • Previously, chemical hazards were evaluated in a more subjective manner. <br /> Chemicals must now go through a specific, prescriptive classification process to determine which hazards are present and which hazard and precautionary statements apply. This can be a lengthy process. <br /> Environmental Hazards are not regulated by MIOSHA. Check with the Michigan Department of Environmental Quality (DEQ) for any employee training requirements for these sections. DEQ Environmental Assistance Center can be reached at (800) 662-9278 from 8 a.m. to 4:30 p.m., Monday through Friday or email: [email_address] <br />
  • Now there are 10 established chemical health classifications; that are further defined and described in Appendix A of the Haz Com Standard. <br /> Appendix A is to be used by manufacturers, importers and distributers to determine if any of their products are classified as a health hazards. If the product is classified as a health hazard in one or more of the 10 health hazard classifications listed on this slide, Appendix A is used to determine the severity of the hazard (or hazard category) under the applicable hazard class. More information noted in the chart on the next slide. <br /> Note: Simple Asphyxiants are not part of the current GHS (international standard) but were specifically included by OSHA as a hazard classification under the 2012 Haz Com Standard. <br />
  • This chart shows the new health hazard classes and the hazard categories that correspond to each of the health hazard classes. Hazard category 1 (or column furthest to the left) is the most hazardous. Hazard categories become less severe as you move to the right in the chart. <br /> Manufacturers, importers and distributers must classify all hazards for their products. <br />
  • Each of the chemical physical classifications are further defined and described in Appendix B of the Haz Com Standard. <br /> Appendix B is to be used by manufacturers, importers and distributers to determine if any of their products are classified as a physical hazard. If the product is classified as a physical hazard in one or more of the physical hazard classifications, Appendix B is used to determine the severity of the hazard (or hazard category). <br />
  • Note: Pyrophoric Gases and Combustible Dust are not part of the GHS (international standard) but were specifically included by OSHA as physical hazard classifications under the 2012 Haz Com Standard. <br />
  • This chart shows the physical hazard classes and the hazard categories that correspond to each of the physical hazard classes. Hazard category 1 (or column furthest to the left) is the most hazardous. Hazard categories become less severe as you move to the right in the chart. <br /> Manufacturers, importers and distributers must classify all hazards for their products. <br />
  • This is an example of the new label style that is to appear on product labels beginning no later than June 1, 2015 (or Dec. 1, 2015 for distributers who still have product in inventory after the June 1, 2015 deadline). <br /> The type of required information is noted in blue. The actual statements and information will vary depending on the specific health and physical classification of the product. <br />
  • Note the difference in the shipping label compared to the container label on the previous slide. Department of Transportation (DOT) requires that additional information be noted on shipping containers. See bottom right corner of the label for shipping. <br /> MIOSHA requires that employees are knowledgeable of both the container and shipping labels. <br />
  • Source: GHS Guide on OSHA website: http://www.osha.gov/dsg/hazcom/ghs.html#3.1 <br /> Figure 4.10 <br /> These are DOT labels and may appear on transport containers depending on the classification of the chemical. Employers are required to train employees on shipping container labels they may encounter on the job. <br />
  • DOT does not view the GHS pictograms as a conflict and it is permissible to have the DOT and GHS pictogram for representing the same hazard. OSHA will not be enforcing the “shall not appear” requirement in Appendix C (C.2.3.3. states “where a pictogram required by DOT under Title 49 of the CFR (code of federal regulations) appears on a shipped container, the pictogram specified in C.4 for the same hazard, shall not appear.” <br />
  • There are 3 pictograms specific to health hazards: exclamation, health hazard (silhouette of a person with starburst on the chest) and skull and crossbones. <br /> There is 1 pictogram that can represents both physical and/or health hazard of corrosive. <br /> There are 4 pictograms specific to physical hazards: exploding bomb, flame, flame over circle (oxidizer) and gas cylinder. <br /> There is 1 for environment: Environmental Hazards are not regulated by MIOSHA. Check with the Michigan Department of Environmental Quality (DEQ) for any employee training requirements for these sections. DEQ Environmental Assistance Center can be reached at (800) 662-9278 from 8 a.m. to 4:30 p.m., Monday through Friday or email: [email_address] <br />
  • The following slides will provide more detail related to the pictograms. <br /> These 2 pictograms are specific to acute toxicity (short-term exposure). The skull and crossbones is for any substance that is classified as having acute toxicity in health hazard category 1-3. The acute toxicity health class, category 4 (least hazardous) is represented by an exclamation mark. <br /> If the substance is properly labeled, these 2 pictograms will never appear on the same label. It will be one or the other with skull and crossbones representing the more severe hazard. <br /> Additional information for labeling and language associated with these pictograms is found in Appendix C of the Haz Com Standard. <br />
  • Most employees should be familiar with the pictogram for corrosion on the left. <br /> The pictogram to the right is called the “health hazard” pictogram and is represented by the silhouette of a person with a starburst across the chest. This is used indicate that the substance is a chronic and/or target organ hazard. <br />
  • The next 2 slides (4 pictograms) represent physical hazards. <br />
  • Note that the corrosive pictogram used to designate corrosion to metal is the same pictogram used for skin corrosion/serious eye damage/eye irritation under the health hazard classification. <br /> Not all health hazards represented by this pictogram are corrosive to metal so it is important to look for additional information on the label and in the SDS. <br /> Oxidizers are chemicals that can emit oxygen and increase the risk of fire. <br />
  • In the past, there have been several signal words that may have been used to indicate a hazard like caution, warning, danger. <br /> The GHS permits the use of only 2 signal words: “Danger” and “Warning”. Only 1 of the signal words is permitted to appear on the label based on the classification of the chemical. <br />
  • Definition of Hazard Statement: <br /> "Hazard statement" means a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. <br /> Manufacturers, importers and distributers use the classification system outlined in GHS to identify which statements must appear in the SDS and on the label found in Appendix C. <br />
  • "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. Precautionary statements can be found in Appendix C. <br />
  • Definition of product identifier: <br /> "Product identifier" means the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS. <br />
  • This is discretionary information that may be provided by the manufacturer, importer or distributer. This information is not required to be on the label; however it will be found in the SDS. <br />
  • Slide is animated to identify each required section/element of the new label. <br />
  • Product Identifier = name or number unique to the chemical listed on the manufacturer label or in SDS. <br /> Note: waste container labeling requirements are covered under EPA/DEQ rules. Contact DEQ for additional information. <br />
  • HMIS = Hazardous Materials Information System (American Coatings Association) <br /> NFPA = National Fire Protection Association <br /> HMIS labeling system incorporates an “*” to inform employees of the presence of a chronic/target organ health effect. NFPA labeling system does not incorporate chronic effects and this must be included on NFPA labeled secondary containers if noted on the original manufacturer container. The health hazard pictogram (silhouette of a person with starburst on chest). <br /> GHS vs. HMIS / NFPA 704 <br /> NFPA & HMIS systems number “4” indicates a severe hazard. <br /> Under GHS Haz Com standard, when a manufacturer, importer, distributer classifies a chemical, a category “4” is the least severe and category “1” in the most severe. <br /> GHS hazard category numbers may be noted in SDS; NOT required to be present on the container label. <br /> ACA made modifications to HMIS ratings in 2001. Reactivity was changed to Physical Hazard and defined ranges modified. System is still 0 = least hazard and 4=greatest hazard) More information available at www.paint.org/programs/hmis.html <br />
  • Manufacturers, importers and distributers may begin using the new 16-section format SDS (follows the ANSI standard) during the transition from the 1994 Haz Com standard and the final 2012 Haz Com standard but no later than June 1, 2015. They are required to provide a revised copy of the MSDS/SDS to the employer anytime changes are made. <br /> Employers are required to maintain copies of all SDSs for the chemicals used and/or stored within the work area. They should have a system to ensure all SDSs are present/accounted and to periodically check for the most current SDS (usually based on revision date) when received from a manufacturer, importer or distributer. <br /> The employer is to maintain a copy of the most current SDS and archive prior MSDSs/SDSs. SDSs are to accessible/available to employees. <br /> As stated previously, if manufacturer is no longer in business, material safety data sheet for the product must kept as long as chemical is onsite/used then archived as required. <br />
  • Manufacturers, importers and distributers may begin using the new 16-section format SDS during the transition from the 1994 Haz Com standard and the final 2012 Haz Com standard but no later than June 1, 2015. They are required to provide a revised copy of the MSDS/SDS to the employer anytime changes are made. <br /> Employers are required to maintain copies of all SDSs for the chemicals used and/or stored within the work area. They should have a system to ensure all SDSs are present/accounted and to periodically check for the most current SDS (usually based on revision date) when received from a manufacturer, importer or distributer. <br /> The employer is to maintain a copy of the most current SDS and archive prior MSDSs/SDSs. SDSs are to be accessible/available to employees. <br /> Appendix D provides additional requirements for the information to be included under each section heading. <br /> Section 1 requires restriction(s) on use. <br /> Section 2 requires: Classification Signal word, symbols, hazard and precautionary statements, Hazards not otherwise classified, Unknown toxicity statements when 1% or more of the components has unknown toxicity. “X percent of the mixture consists of ingredients of unknown toxicity.” <br /> Section 3 requires percentage. <br /> MIOSHA will not enforce sections 12 – 15. <br /> Sections 12-15 are not regulated by MIOSHA. Check with the Michigan Department of Environmental Quality (DEQ) for any employee training requirements for these sections. DEQ Environmental Assistance Center can be reached at (800) 662-9278 from 8 a.m. to 4:30 p.m., Monday through Friday or email: [email_address] <br />
  • Section 1 <br /> The required information consists of: <br /> • Product identifier used on the label and any other common names or synonyms by which the <br /> substance is known. <br /> • Name, address, phone number of the manufacturer, importer, or other responsible party, and <br /> emergency phone number. <br /> • Recommended use of the chemical (e.g., a brief description of what it actually does, such <br /> as flame retardant) and any restrictions on use (including recommendations given by the <br /> supplier). <br /> Section 2 <br /> The required information consists of: <br /> • The hazard classification of the chemical (e.g., flammable liquid, category1). <br /> • Signal word. <br /> • Hazard statement(s). <br /> • Pictograms (the pictograms or hazard symbols may be presented as graphical reproductions <br /> of the symbols in black and white or be a description of the name of the symbol (e.g., skull <br /> and crossbones, flame). <br /> • Precautionary statement(s). <br /> • Description of any hazards not otherwise classified. <br /> • For a mixture that contains an ingredient(s) with unknown toxicity, a statement describing how <br /> much (percentage) of the mixture consists of ingredient(s) with unknown acute toxicity. Please <br /> note that this is a total percentage of the mixture and not tied to the individual ingredient(s). <br />
  • Section 3 <br /> The required information consists of: <br /> Substances <br /> • Chemical name. <br /> • Common name and synonyms. <br /> • Chemical Abstracts Service (CAS) number and other unique identifiers. <br /> • Impurities and stabilizing additives, which are themselves classified and which contribute to <br /> the classification of the chemical. <br /> Mixtures <br /> • Same information required for substances. <br /> • The chemical name and concentration (i.e., exact percentage) of all ingredients which are <br /> classified as health hazards and are: <br /> ° Present above their cut-off/concentration limits or <br /> ° Present a health risk below the cut-off/concentration limits. <br /> • The concentration (exact percentages) of each ingredient must be specified except <br /> concentration ranges may be used in the following situations: <br /> ° A trade secret claim is made, <br /> ° There is batch-to-batch variation, or <br /> ° The SDS is used for a group of substantially similar mixtures. <br /> Chemicals where a trade secret is claimed <br /> • A statement that the specific chemical identity and/or exact percentage (concentration) of <br /> composition has been withheld as a trade secret is required. <br /> Section 4 <br /> The required information consists of: <br /> • Necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact, <br /> and ingestion). <br /> • Description of the most important symptoms or effects, and any symptoms that are acute or <br /> delayed. <br /> • Recommendations for immediate medical care and special treatment needed, when necessary. <br />
  • Section 5 <br /> The required information consists of: <br /> • Recommendations of suitable extinguishing equipment, and information about extinguishing <br /> equipment that is not appropriate for a particular situation. <br /> • Advice on specific hazards that develop from the chemical during the fire, such as any <br /> hazardous combustion products created when the chemical burns. <br /> • Recommendations on special protective equipment or precautions for firefighters. <br /> Section 6 <br /> The required information may consist of recommendations for: <br /> • Use of personal precautions (such as removal of ignition sources or providing sufficient <br /> ventilation) and protective equipment to prevent the contamination of skin, eyes, and clothing. <br /> • Emergency procedures, including instructions for evacuations, consulting experts when <br /> needed, and appropriate protective clothing. <br /> • Methods and materials used for containment (e.g., covering the drains and capping <br /> procedures). <br /> • Cleanup procedures (e.g., appropriate techniques for neutralization, decontamination, cleaning <br /> or vacuuming; adsorbent materials; and/or equipment required for containment/clean up). <br />
  • Section 7 <br /> The required information consists of: <br /> • Precautions for safe handling, including recommendations for handling incompatible <br /> chemicals, minimizing the release of the chemical into the environment, and providing advice <br /> on general hygiene practices (e.g., eating, drinking, and smoking in work areas is prohibited). <br /> • Recommendations on the conditions for safe storage, including any incompatibilities. Provide <br /> advice on specific storage requirements. <br /> Section 8 <br /> The required information consists of: <br /> • OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial <br /> Hygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limit used or <br /> recommended by the chemical manufacturer, importer, or employer preparing the safety data <br /> sheet, where available. <br /> • Appropriate engineering controls (e.g., use local exhaust ventilation, or use only in an enclosed <br /> system). <br /> • Recommendations for personal protective measures to prevent illness or injury from exposure <br /> to chemicals, such as personal protective equipment (PPE) (e.g., appropriate types of eye, face, <br /> skin or respiratory protection needed based on hazards and potential exposure). <br /> • Any special requirements for PPE, protective clothing or respirators (e.g., type of glove material, <br /> such as PVC or nitrile rubber gloves; and breakthrough time of the glove material). <br />
  • Section 9 <br /> The minimum required information consists of: <br /> • Appearance (physical state, color, etc.); • Upper/lower flammability or explosive limits; <br /> • Odor;• Vapor pressure; <br /> • Odor threshold; • Vapor density; <br /> • pH; • Relative density; <br /> • Melting point/freezing point; • Solubility(ies); <br /> • Initial boiling point and boiling range; • Partition coefficient: n-octanol/water; <br /> • Flash point; • Auto-ignition temperature; <br /> • Evaporation rate; • Decomposition temperature; and <br /> • Flammability (solid, gas); • Viscosity. <br /> The SDS may not contain every item on the above list because information may not be relevant or is not available. When this occurs, a notation to that effect must be made for that chemical property. Manufacturers may also add other relevant properties, such as the dust deflagration index (Kst) for combustible dust, used to evaluate a dust’s explosive potential. <br /> Section 10 <br /> The required information consists of: <br /> Reactivity <br /> • Description of the specific test data for the chemical(s). This data can be for a class or family of the chemical if such data adequately represent the anticipated hazard of the chemical(s), where available. <br /> Chemical stability <br /> • Indication of whether the chemical is stable or unstable under normal ambient temperature and conditions while in storage and being handled. <br /> • Description of any stabilizers that may be needed to maintain chemical stability. <br /> • Indication of any safety issues that may arise should the product change in physical appearance. <br /> Other <br /> • Indication of the possibility of hazardous reactions, including a statement whether the chemical will react or polymerize, which could release excess pressure or heat, or create other hazardous conditions. Also, a description of the conditions under which hazardous reactions may occur. <br /> • List of all conditions that should be avoided (e.g., static discharge, shock, vibrations, or environmental conditions that may lead to hazardous conditions). <br /> • List of all classes of incompatible materials (e.g., classes of chemicals or specific substances) with which the chemical could react to produce a hazardous situation. <br /> • List of any known or anticipated hazardous decomposition products that could be produced because of use, storage, or heating. (Hazardous combustion products should also be included in Section 5 (Fire-Fighting Measures) of the SDS.) <br />
  • Section 11 <br /> The required information consists of: <br /> • Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact). <br /> The SDS should indicate if the information is unknown. <br /> • Description of the delayed, immediate, or chronic effects from short- and long-term exposure. <br /> • The numerical measures of toxicity (e.g., acute toxicity estimates such as the LD50 (median <br /> lethal dose)) - the estimated amount [of a substance] expected to kill 50% of test animals in a <br /> single dose. <br /> • Description of the symptoms. This description includes the symptoms associated with <br /> exposure to the chemical including symptoms from the lowest to the most severe exposure. <br /> • Indication of whether the chemical is listed in the National Toxicology Program (NTP) <br /> Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the <br /> International Agency for Research on Cancer (IARC) Monographs (latest editions) or found <br /> to be a potential carcinogen by OSHA. <br /> Sections 12-15 are not regulated by MIOSHA. Check with the Michigan Department of Environmental Quality (DEQ) for any employee training requirements for these sections. DEQ Environmental Assistance Center can be reached at (800) 662-9278 from 8 a.m. to 4:30 p.m., Monday through Friday or email: [email_address] <br /> Section 16, Other information, includes the date of preparation or last revision. <br /> *Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)). <br /> See Appendix D of 1910.1200 for a detailed description of SDS contents. <br />
  • HMIS and NFPA secondary container labeling systems guidance might appear in this section of the SDS. <br />
  • MIOSHA Act 154 requires that posters noting the location and receipt of new or revised SDSs be placed in the work area. <br /> Act 154 will be revised to be in compliance with GHS/Haz Com changes. This change may take some time to be effective. <br /> This slide pictures the posters as they will appear with the anticipated change in wording from MSDS to SDS. <br />
  • Employers must provide facility specific instruction to employees as described on this slide and the next slide to be compliant with the Haz Com training requirements. <br /> Employers must also maintain and periodically review the written Haz Com program for the facility which contains all of the information on this slide and the next slide. <br />
  • Employee training requirements have been met if the employer has provided the contents of this training program including the facility specific supplemental training. <br />
  • This slide highlights some of the additional resources available on the Federal OSHA website. <br /> OSHA Haz Com Web Page: www.osha.gov/dsg/hazcom/index.html <br /> OSHA Guide to GHS: www.osha.gov/dsg/hazcom/ghs.html <br />
  • This slide highlights some of the additional resources available on the MIOSHA website. <br /> State-wide Outreach seminars will be held. Additional details can be found on the MIOSHA CET training calendar <br /> http://www.michigan.gov/lara/0,4601,7-154-61256_11407_15317-40999--,00.html <br /> The link to the CET DVD lending library is <br /> http://www.michigan.gov/lara/0,4601,7-154-61256_11407_30453-40855--,00.html <br />

 Hazard Communication Training Program by MIOSHA Hazard Communication Training Program by MIOSHA Presentation Transcript

  • Prepared by Consultation Education & Training (CET) Division Michigan Occupational Safety & Health Administration Michigan Department of Licensing and Regulatory Affairs www.michigan.gov/miosha (517) 322-1809 (Revised: 08/23/13)
  • Agenda Overview of changes to the MIOSHA Part 42, 92 and 430: Hazard Communication Standard (Haz Com) Labeling requirements Safety Data Sheets (SDS) format – 16 sections Supplemental Employee Training (to be provided by employer)
  • Why the Change to Haz Com? To align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) adopted by 67 nations To provide a common and coherent approach to classifying chemicals • Reduce confusion and increase understanding of the hazards • Facilitate training • Help address literacy problems
  • Who is Affected? Manufacturers, Distributors, Importers Change SDS information and format Change container labeling Employers Training employees on changes to: SDS (change from MSDS to SDS and 16-section format) Container Labels (including secondary containers) Employees Recognize and understand hazards based on: Information in new SDS format Pictograms on container labels Precautionary and hazard statements
  • Other Standards Affected – Health (signage requirements) Asbestos Carcinogens Vinyl Chloride Inorganic Arsenic Lead Cadmium Benzene Coke Oven Emissions Acrylonitrile Ethylene Oxide Formaldehyde Methylenedianiline DANGER WARNING LEAD WORK AREA POISON NO SMOKING OR EATING New Sign “LEAD” LEAD MAY DAMAGE FERTILITY OR THE UNBORN CHILD CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM DO NOT EAT, DRINK OR SMOKE IN THIS AREA
  • Other Standards Affected Flammable and Combustible Liquids Spray Finishing using Flammable and Combustible Materials Process Safety Management of Highly Hazardous Chemicals (PSM) Hazardous Waste Operations and Emergency Response (HAZWOPER) Hazardous Work In Laboratories Dipping and Coating Operations Welding, Cutting and Brazing Employee Medical Records and Trade Secrets
  • Effective Dates and Requirements Effective Completion Date Requirement(s) Responsible Party December 1, 2013 Train employees on the new label elements and SDS format Employers June 1, 2015 Compliance with all modified provisions of the final rule except: Chemical manufacturers, importers, distributors, and employers December 1, 2015 The distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label Distributor June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified hazards [and affected vertical standard specific signage] Employer Transition Period: 12/2012 to the effective completion dates noted above May comply with either MIOSHA Part 42, 92 and 430 (final standard), or the current standard, or both Chemical manufacturers, importers, distributors, and employers
  • Chemical Classifications Chemicals will be classified using a harmonized system that provides standardized language for: Health Hazard Categories Physical Hazard Categories Environmental Hazard Categories* *Not regulated by MIOSHA.
  • Chemical Classifications: Health Hazards Acute Toxicity Skin Corrosion/Irritation Respiratory or Skin Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Specific Target Organ Toxicity – Single Exposure Specific Target Organ Toxicity – Repeated Exposure Aspiration Simple Asphyxiants
  • Chemical Classifications: Health Hazards Hazard Class 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 Simple Asphyxiants Hazard Category 1 1A 1 1 1A 1A 1A 2 1B 2A 3 1C 2B 1B 1B 1B 2 2 2 1 2 3 1 2 1 Single Category 4 2 Lactation
  • Chemical Classifications: Physical Hazards Explosives Flammable Aerosols Oxidizing Gases Gases under Pressure Compressed Gases Liquefied Gases Refrigerated Liquefied Gases Dissolves Gases
  • Chemical Classifications: Physical Hazards (continued) Flammable Liquids Flammable Solids Self-Reactive Chemicals Pyrophoric Liquids Pyrophoric Solid Pyrophoric Gases Self-heating Chemicals Chemicals, which in contact with water, emit flammable gases
  • Chemical Classifications: Physical Hazards (continued) Oxidizing Liquids Oxidizing Solid Organic Peroxides Corrosive to Metals Combustible Dusts
  • Chemical Classifications: Physical Hazards Hazard Class Explosives Flammable Gases Flammable Aerosols Oxidizing Gases Gases under Pressure Compressed gases Liquefied gases Refrigerated liquefied gases Dissolved gases Flammable Liquids Flammable Solids Self-Reactive Chemicals Pyrophoric Liquids Pyrophoric Solids Pyrophoric Gases Self-Heating Chemicals Chemicals in which contact with water emit flammable gases Oxidizing Liquids Oxidizing Solids Organic Peroxides Corrosive to Metals Combustible Dust Unstable Explosives 1 1 1 Hazard Category Div 1.1 Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6 3 4 Type C Type D Type E Type F Type G Type D Type E Type F Type G 2 2 1 1 1 Type A 1 1 Single Category 1 2 2 Type B 1 2 3 1 1 Type A 1 2 2 Type B 3 3 Type C Single Category 2
  • Labels There are several new label elements: Symbols called “Pictograms” Signal Words Hazard Statements Precautionary Statements Product Identification Supplier/Manufacturer Identification www.osha.gov/Publications/HazComm_QuickCard_Labels.htm
  • Labels: Shipping Shipping Container Label (55 gallon/200 liter drum) Effective June 1, 2015 all shipping labels will be required to have all GHS label elements Pictograms within DOT label DOT Shipping Flammable liquids, toxic, n.o.s. (contains XYZ) UN 1992
  • Transport "Pictograms" Flammable Liquid Flammable Gas Flammable Aerosol Flammable solid Self-Reactive Substances Pyrophorics (Spontaneously Combustible) Self-Heating Substances Substances, which in contact with water, emit flammable gases (Dangerous When Wet) Oxidizing Gases Oxidizing Liquids Oxidizing Solids Explosive Division 1.4 Explosive Division 1.5 Explosive Division 1.6 Compressed Gases Acute Toxicity (Poison): Oral, Dermal, Inhalation Corrosive Marine Pollutant Explosive Divisions 1.1, 1.2, 1.3 Organic Peroxides
  • DOT and MIOSHA Labels DOT labels may take precedence over similar GHS pictograms for shipping containers. DOT does not have labels that correspond to the “Health Hazard” or the “Acute Toxicity” (less severe = exclamation mark).
  • Labels: Pictograms There are 9 pictograms. Only 8 are regulated by MIOSHA Health Hazards Physical Hazards Environmental Hazards (Regulated by DEQ) DEQ
  • Labels: Pictograms – Health Hazards Acute toxicity (Severe) Acute = short-term effect Acute toxicity (Less Severe): Irritant Dermal sensitizer Acute toxicity (harmful) Narcotic effects Respiratory tract irritation
  • Labels: Pictograms – Health Hazards (continued) Skin corrosion Serious eye damage/ Eye irritation Carcinogen Respiratory sensitizer Reproductive toxicity Target organ toxicity Mutagenicity Aspiration Hazard
  • Labels: Pictograms – Physical Hazards Explosives Self reactives Organic peroxides Flammables Self reactives Pyrophorics Self heating Emits flammable gas Organic peroxides
  • Labels: Pictograms – Physical Hazards (continued) Corrosive to Metals Oxidizer Gases under Pressure
  • Labels: Signal Word These are words used to indicate the severity of the hazard and alert employees to the potential hazard. Only 2 signal words will appear: “DANGER”(more severe hazard) “WARNING” (less severe hazard) Not all labels will have a signal word. Some chemicals are not hazardous enough to require that a signal word appear on the label.
  • Labels: Hazard Statement There are specific hazard statements that must appear on the label based on the chemical hazard classification. Examples: Flammable liquid and vapor Causes skin irritation May cause cancer
  • Labels and other forms of warning – Precautionary Statements Recommended measures related to: Prevention Response Storage Disposal Examples: Wear respiratory protection Wash with soap and water Store in a well ventilated place Not a mandate for employers/employees to follow.
  • Label: Identification Product identification (i.e. name of product) Supplier identification: Address Telephone number
  • Label: Other information Other information that may be included on the label: Physical state Color Hazards not otherwise classified Route of exposure Storage and disposal Hazard prevention and emergency response instructions
  • Pictograms (Flammable and Acute Toxicity – Severe) ToxiFlam (Contains: XYZ)    Product Identifier Signal Word Danger! Toxic If Swallowed, Flammable Liquid and Vapor Hazard Statements Do not eat, drink or use tobacco when using this product. Wash hands thoroughly after handling. Keep container tightly closed. Keep away from heat/sparks/open flame. - No smoking. Wear protective gloves and eye/face protection. Ground container and receiving equipment. Use explosion-proof electrical equipment. Take precautionary measures against static discharge. Use only non-sparking tools. Store in cool/well-ventilated place. IF SWALLOWED: Immediately call a POISON CONTROL CENTER or doctor/physician. Rinse mouth. Precautionary In case of fire, use water fog, dry chemical, CO2, or "alcohol" foam. Statements Supplemental Information See Safety Data Sheet for further details regarding safe use of this product. MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 966 6666 Supplier Identification
  • Secondary Container Labels Excerpt from the Hazard Communication Standard (f):  (6) Workplace labeling. Except as provided in paragraphs (7) and (8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either:  (i) The information specified under paragraphs (1)(i) through (v) of this section for labels on shipped containers [GHS Label]; or,  (ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical [e.g. HMIS, NFPA or other label system].
  • Labels: Secondary containers Must be consistent with the revised Haz Com standard No conflicting hazard warnings or pictograms. May use written materials (e.g., signs, placards, etc.) in lieu of affixing labels to individual stationary process containers. Employer can use GHS compliant labels (same as shipping). HMIS Label HEALTH FIRE PHYSICAL HZ PPE NFPA Label Must include notation of chronic health effects
  • Safety Data Sheets Under the new Haz Com Standard, Material Safety Data Sheets (MSDS) are now called Safety Data Sheets (SDS). All SDSs will have a consistent 16-section format. Employers must ensure that SDSs are readily accessible to employees. Safety Material Data Safety Sheets Data Sheets
  • Safety Data Sheets (SDSs) New 16-section standardized SDS format required (ANSI Z400.1) Section 1 – Identification Section 2 – Hazard(s) identification Section 10 – Stability and Reactivity Section 11 – Toxicological Information Section 3 – Composition / Information on Ingredients Section 12 – Ecological Information* Section 4 – First-aid Measures Section 5 – Fire-fighting Measures Section 6 – Accidental Release Measures Section 7 – Handling and Storage Section 8 – Exposure Controls / Personal Protection Section 9 – Physical and Chemical Properties Section 13 – Disposal Consideration* Section 14 – Transport Information* Section 15 – Regulatory Information* Section 16 – Other information including date of preparation of last revision *Sections outside of MIOSHA jurisdiction but inclusion of these sections is necessary for a GHS compliant SDS
  • Safety Data Sheets (continued) Section 1 – Identification: Identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier. Section 2 - Hazards Identification: Hazards of the chemical presented on the SDS Appropriate warning information associated with those hazards.
  • Safety Data Sheets (continued) Section 3 – Composition / Ingredients: Identifies the ingredient(s) contained in the product indicated on the SDS, including: impurities and stabilizing additives. information on substances, mixtures, and all chemicals where a trade secret is claimed. Section 4 - First-Aid Measures: Describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical.
  • Safety Data Sheets (continued) Section 5 – Fire-Fighting Measures: Provides recommendations for fighting a fire caused by the chemical. Section 6 - Accidental Release Measures: Provides recommendations: Appropriate response to spills, leaks, or releases, (e.g. containment and cleanup practices) Response for large vs. small spills, if different.
  • Safety Data Sheets (continued) Section 7 – Handling and Storage: Provides guidance on the safe handling practices and conditions for safe storage of chemicals. Section 8 – Exposure Controls / Personal Protection: Indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure.
  • Safety Data Sheets (continued) Section 9 – Physical and Chemical Properties: Identifies physical and chemical properties associated with the substance or mixture. Section 10 – Stability and Reactivity Describes the reactivity hazards of the chemical and the chemical stability information. Includes: reactivity, chemical stability, and other.
  • Safety Data Sheets (continued) Section 11 - Toxicological Information: Identifies toxicological and health effects information or indicates is data unavailable. Section 12 – Ecological Information* Section 13 – Disposal Consideration* Section 14 – Transport Information* Section 15 – Regulatory Information* *Sections are outside of MIOSHA jurisdiction but must be included for a GHS compliant SDS.
  • Safety Data Sheets (continued) Section 16 – Other Information Indicates when the SDS was prepared or when the last known revision was made. The SDS may also state where the changes have been made to the previous version.
  • Revised Posters – MSDS to SDS
  • Have I completed the training? Maybe…………
  • Has the following been provided by the employer? Employers must provide employees with the details of the facility specific hazard communication program: Location and availability of written program and SDSs Specific information related to chemicals in the facility:  Physical Hazards;  Health Hazards;  Hazards not otherwise classified.
  • Has the following been provided by the employer? (continued) Chemical list, location and use of hazardous chemicals Secondary container labeling system Specific procedures to follow to protect employees from the chemical hazard Methods used to detect the presence or release of hazardous chemicals (sensor alarms, odors, visual other monitoring devices) ?
  • Federal OSHA Resources Haz Com Web Page - www.osha.gov/dsg/hazcom/index.html Regulatory Haz Com 2012 Final Rule Haz Com Comparison: Haz Com 1994 and 2012 Side-by-side Redline Strikeout of the Regulatory Text FAQs Guidance OSHA Briefs Fact Sheet Quick Cards Labeling Safety Data Sheets Pictograms Effective Dates OSHA Guide to GHS www.osha.gov/dsg/hazcom/ghs.html GHS documents (links to purple book)
  • MIOSHA Resources GHS Webpage on MIOSHA Website www.michigan.gov/lara/0,4601,7-154-61256_11407284831--,00.html Employee Training PowerPoint CET library handouts:  CET-5531 - GHS Overview of Major Changes  CET-5532 – Lists other affected Standards  CET-5533 – Signage Changes CET DVDs/Video Lending library services State-wide Outreach seminars Guidance documents & Revised posters
  • Training Summary Today’s training program included: Overview of changes to the MIOSHA Part 42, 92 and 430: Hazard Communication Standard (Haz Com) Labeling requirements Safety Data Sheets (SDS) format – 16 categories Details of the facility specific hazard communication program Resources
  • Questions Contact MIOSHA for information or assistance: MIOSHA Consultation Education and Training 7150 Harris Drive, P.O. Box 30643 Lansing, Michigan 48909-8143 (517) 322-1809 www.michigan.gov/miosha