The update to the OSHA regulation concerning Hazard Communication. This law commonly known as The Right To Know Law, is now The Right To Understand Law. Gone are MSDS forms and welcome to the new SDS forms.
If you missed the OSHA deadline to be updated, get in compliance now. Do you need a certificate of completion? Contact us b_conner@kudzusafety.com. All it takes is a short quiz and $20.00.
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Haz com 2012 ghs
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Hazard Communication
2012
Globally Harmonized System
(GHS) of classification and
labeling of chemicals
UPDATED STANDARD
3. Kudzu Health & Safety
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Why did the
Occupational Safety
and Health
Administration (OSHA)
determine that a change
to the standard was
needed?
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Quite simply to bring us into
compliance with what most
Countries have already been
doing for years.
5. Kudzu Health & Safety
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Why do we care about
what other Countries are
doing? Doesn’t OSHA
already have a well put
together HAZCOM
program?
6. Kudzu Health & Safety
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YES!
They Do!
The Facts
• First Hazcom
standard – 1983
• Updated in 1994.
• Called the “Right To
Know” Law.
• Required labels and
MSDS for hazardous
chemicals.
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However
The
Problems
• Hazard
determinations can
be confusing to the
average reader.
• No set format for
MSDS which
created an
unlimited number of
confusing forms in
the workplace.
• Label format on
containers was left
up to the preparer,
causing confusion.
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Besides,
We live and work in a
globally connected
economy.
AND…
The United States is a
major importer and
exporter of chemicals.
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NOW…
The U.S.A. has finally joined
other major importers and
exporters of chemicals in a
universal safety standard to
protect workers.
67 other Countries follow the U.N.’s
GHS system.
10. Kudzu Health & Safety
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Furthermore,
OSHA did not replace, delete or
stop enforcing the 1994 Hazard
Communication standard.
The 1994 standard was modified to
be in line with the GHS or “Globally
Harmonized System of
Classification and Labeling of
Chemicals.
11. Kudzu Health & Safety
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“Sounds great,
but I am still
confused
about this GHS
thing.”
“Can you help
me understand
this global
system?”
12. Kudzu Health & Safety
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Sure! It actually makes things
better and easier to
understand.
The GHS system is and
is not
NEXTNEXT
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• A set of Guidelines developed
by the United Nations.
• A system of Best Practices.
• A standardized way to classify
chemicals and hazards.
• Standardized labels and
Safety Data Sheets.
What it
is:
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• A law or regulation.
• A system that must be
followed; instead it is
voluntary . Countries can
adopt all, part or none of the
GHS system.
What it is not:
or
Let’s Do It! Not for us.
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Since 1983, the Hazard
Communication standard has
always had the worker’s safety
at the forefront.
Alignment with the GHS
continues to reinforce worker
safety by placing more focus
on employees being able to
understand the hazards
present.
16. Kudzu Health & Safety
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So, how does alignment with the
GHS increase worker safety?
• It has specific criteria for health
and physical hazards.
• New Container Labels.
• Safety Data Sheets (SDS)
instead of MSDS.
• Information and Training.
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Let me break it down a little further. Just
so everyone understands why I think this
is a change for the better.
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Doc, give it to
me straight.
Am I going to
survive the
new HAZCOM
2012?
19. Kudzu Health & Safety
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Not only will he (and you)
survive the updated HAZCOM
program, but you will now have
more information at your
fingertips!
As I said before, alignment with the
GHS creates a safer workplace.
Now can be called “The Right To
Understand Law”.
20. Kudzu Health & Safety
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Remember the four changes
that will lead to a safer
workplace?
21. Kudzu Health & Safety
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One major change in the Hazard
Communication standard is how
physical and health issues are
classified.
1994 US 2012 GHS
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The Way We Were
1994 Standard
Hazard Determinations had definitions of
the hazard.
Evaluator determined whether or not the
data on the chemical met those definitions.
Performance oriented approach that gave
parameters for evaluation. But, not
detailed or specific criteria.
23. Kudzu Health & Safety
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Where We Are Now
2012 GHS Standard
Has specific criteria for each physical and
health hazard.
Detailed instructions for hazard
determination and evaluation.
Establishes both hazard classes and
hazard categories.
Detailed appendixes have been added.
24. Kudzu Health & Safety
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As you can see, the GHS
HazCom program has
advantages over the “old” or
“current” system used in the
United States.
Once in complete effect in the U.S.,
the GHS will eliminate the
uncertainty that now exist in hazard
determination.
25. Kudzu Health & Safety
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Old School
HazCom
Uses Hazard Determination,
which is NOT standardized
and can vary from evaluator to
evaluator. Determination
?
26. Kudzu Health & Safety
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New School
HazCom
Instead of the “old”
hazard determination, the
GHS program uses the
more safety oriented
“Hazard Classifications”
and “Hazard Categories”.
27. Kudzu Health & Safety
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• Just like before, the new
program still requires that
chemical hazards be evaluated.
• The change is in the way it is
performed. As mentioned
before there are now strict
guidelines for how each health
and physical hazard and how
they are evaluated.
28. Kudzu Health & Safety
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• The GHS covers any mixture or
substance that falls within the
specified criteria.
• It establishes “Hazard Classes” and
“Hazard Categories”.
• The established Classes are divided
into the established Categories.
29. Kudzu Health & Safety
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What is the purpose of adding the
Categories into the Classes:
It will make it easier to obtain
additional information that may be
related to the appropriate
response of a chemical hazard.
30. Kudzu Health & Safety
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These revisions have been
written into OSHA’s Hazard
Communication regulation and
placed in paragraph (D).
Also added were extensive
appendixes that address the criteria
for each health and physical effect.
31. Kudzu Health & Safety
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Another major change to the
HazCom program are Labels.
Under the 1994 standard:
• The label preparer had to
provide the identity of the
chemical and any hazard
warnings.
• Could be done in varying ways.
• Method was left up to preparer.
32. Kudzu Health & Safety
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Under the GHS or OSHA HazCom
2012 standard, chemical labels
must follow these rules.
• Once hazard classification is
completed, the standard will specify
which information must be provided on
label.
• This is done for each “Hazard Class”
and “Hazard Category”.
• Labels must contain certain elements.
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“An updated
program,
means
updated
(new) labels”
What is new?
What’s
different?
34. Kudzu Health & Safety
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Let’s start by talking about the labels you
are accustomed to seeing…..
It’s pretty simple…….there are only two
requirements.
1. Identity of Chemical
2. Appropriate Hazard
Warnings
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…and now, here is what you will begin
to see.
Instead of two requirements for
container labels, there are now six (6).
36. Kudzu Health & Safety
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Wow! Six requirements
instead of the current two?
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Pictograms Signal Word
Hazard Statements
Precautionary
Statements
Product Identifier
Supplier Identification
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Sample GHS Label
39. Kudzu Health & Safety
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The Parts of the Label
Pictogram
s
Signal
Word
Product
Identifier
Hazard
Statement
Precautionary
Statements
Supplier
Identificatio
n
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Is there anything special about the
Pictograms?
YES!
1. Be in the shape of a square and set on a
point.
2. Have a black hazard symbol on a white
background.
3. Have a red frame that is wide enough to
be clearly visible.
All three must be present
Pictograms must follow these rules.
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Let’s take a look
at the different
Pictograms you
will see and want
they mean.
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Flame
Health Hazards
• Flammables
• Pyrophorics
• Self-Heating
• Emits Flammable Gas
• Self-Reactives
• Organic Peroxides
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Exploding Bomb
Health Hazards
• Explosives
• Self-Reactives
• Organic Peroxides
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Skull and
Crossbones
Health Hazards
• Acute Toxicity (fatal or toxic)
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Corrosion
Health Hazards
• Skin Corrosion/Burns
• Eye Damage
• Corrosive to Metals
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Gas Cylinder
Health Hazards
• Gases Under Pressure
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Health Hazard
Health Hazards
• Carcinogen
• Mutagenicity
• Reproductive Toxicity
• Respiratory Sensitizer
• Target Organ Toxicity
• Aspiration Toxicity
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Environment
Health Hazards
• Aquatic Toxicity
(Non-Mandatory Label)
Environmental hazards are not under
OSHA’s jurisdiction.
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Exclamation Mark
Health Hazards
• Irritant (skin and eye)
• Skin Sensitizer
• Acute Toxicity
• Narcotic Effects
• Respiratory Tract Irritant
• Hazardous to Ozone Layer
(Non-Mandatory)
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Blank red diamonds are
not permitted on a label.
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In the United States certain
items covered under the
Globally Harmonized System
are regulated by other
government agencies. OSHA
defers to that agency for
enforcement.
54. Kudzu Health & Safety
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What about
workplace labeling
requirements?
Do they need to
have the same
labeling as
shipments from
Manufacturers and
Distributors?
55. Kudzu Health & Safety
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OSHA has retained the flexibility that is
present in the current standard.
Employers may use the same label that
is found on shipment containers or an
alternative label.
Label used must conform to the
HAZCOM standards for information that
is contained on them.
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Two common alternative labels
are:
NFPA 704 HMIS
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No matter which labeling
system is used, the
information contained on it
MUST be consistent with
the HAZCOM 2012 (GHS)
standard.
58. Kudzu Health & Safety
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Even if using the NFPA 704 or
Hazardous Material Information
System (HMIS)
There can be no conflicting
hazard warnings or
pictograms.
It must match information on
shipping label.
59. Kudzu Health & Safety
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Sounds good! So OSHA is now
on board with the UN’s Global
program for curving injuries and
deaths from hazardous chemicals.
We can finally communicate with
other Countries that use the GHS.
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What about the Material Data
Safety Sheets or MSDS? Are
they going to change also?
That sounds like a lot work for
some companies.
YES!
61. Kudzu Health & Safety
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2015
The year that all
manufacturers must
be using the new SDS
format instead of the
MSDS format.
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What is wrong with the
current MSDS? Are we
just dropping the “M”
or changing more?
More is changing. The
current MSDS leaves the
format up to each
preparer of the form.
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This non-standardized
approach results in difficult
to read and difficult to
understand MSDS’ .
The GHS program
standardizes how Safety
Data Sheets look and where
information is contained on
them.
64. Kudzu Health & Safety
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The Safety Data Sheets or
SDS is largely the same as the MSDS, except it
uses a consistent, user-friendly format. It also
has a 16 section format. Gone is the confusion
of the MSDS. Finally! They will all look the
same!
65. Kudzu Health & Safety
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Alright…..So what kinds of things
will I see on this new Safety Data
Sheet (or SDS)?
First of all, it must be written in English.
Although it can contain other languages
as well.
66. Kudzu Health & Safety
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Other Information Included on
SDS.
Properties of each chemical.
Physical, health and environmental
health hazards.
Protective measures.
Safety precautions for handling,
storage, and transporting chemicals.
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Also….
• Preparers may also include
additional information in
sections.
• Specific minimum information
detailed in Appendix D of the
HazCom standard.
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Let’s take a look at the
different sections on the
Safety Data Sheet and what
information is contained in
them.
Remember: The SDS is easier to
understand than our current MSDS
and they must all be uniform in
design and appearance.
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The first 8 sections are dedicated to
the user being able to find important
information quickly.
It is designed to assist workers when
an emergency occurs, such as a
medical emergency, injury or fire.
Also, this uniform approach is a
huge improvement over the current
MSDS.
73. Kudzu Health & Safety
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If the preparer does not find any relevant
information for a section or field, he or she
must state that “no applicable information
was found” in the blank field or section.
75. Kudzu Health & Safety
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Let’s take a look at what are the
required section numbers and
what information must be
contained within them.
REMEMBER:
The GHS format of the Safety Data
Sheet will be required by June 2015.
However, you should expect to see
this form much earlier, since other
Countries have already been using it.
77. Kudzu Health & Safety
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A standardized form (from every
supplier) with all the needed information
in the same location on every Safety Data
Sheet. That is improvement over OSHA’s
current non-standardized requirements.
78. Kudzu Health & Safety
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The GHS and the HazCom 2012 standard
is intended to be a living document.
Prior to the adoption of the UN’s Globally
Harmonized System, OSHA has only
updated the HazCom standard twice.
Now, any updates will occur on a two-
year cycle.
79. Kudzu Health & Safety
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In addition to the new labels with the
pictograms and added information,
the Safety Data Sheets and the new
chemical classifications, OSHA is
requiring training.
All employees who are potentially
exposed to chemicals in the
workplace, must receive this training
by December 1, 2013.
80. Kudzu Health & Safety
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But, OSHA is requiring
the training by
December 1, 2013
because workers will
begin to see the new
labels and SDSs
sooner.
81. Kudzu Health & Safety
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OSHA expects alignment with
the GHS to:
• Prevent 43 deaths.
• Prevent 585 injuries and
diseases.
• Save $475.2 million from
improvements.
83. Kudzu Health & Safety
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Hopefully, you can see the
benefit of the U.S.A. joining
the many other Countries by
aligning with the United
Nations GHS program.
It just makes good sense!
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If you have questions, please contact us
for information.
(804) 520-5777
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Editor's Notes
Talk about brain death. Response times. Something vs nothing