The summary provides an overview of the key differences between the Hazard Communication System (HAZCOM) and the Globally Harmonized System (GHS). HAZCOM currently requires hazard information and labels for chemicals in the US, while GHS aims to standardize this globally through harmonized criteria, labels, and safety data sheet formats. GHS implementation is ongoing, with a final US rule expected in the next 18 months. Companies can begin preparing by obtaining GHS labels, reformatting safety data sheets, and training workers on the new standardized system.

1. An Overview of globally harmonized system(GHS) TALON SAFETY, LLC

3. Address stakeholder concerns regarding the need for a standardized format for MSDS; and,

4. Increase understanding by using standardized pictograms and harmonized hazard statements.GHS will reduce confusion and thus reduce worker safety and health.

5. Hazcom vs. GHS There are many differences in the Hazard Communication System (HCS/HAZCOM) and the Globally Harmonized System (GHS). It is recommended that you review the changes and the implementation as it specifically affects your organization.

6. HAZCOM Hazard Communication System OSHA estimates: 7 million workplaces 100 million employees 945,000 hazardous chemical products

7. GLOBALLY HARMONIZED SYSTEM GHS – Prepared and first implemented by United Nations Economic Commission for Europe in 2003 The third revision was published in July 2009

8. GLOBALLY HARMONIZED SYSTEM Implementation Current status NPRM Comment Period ended 12/29/2009 Hearing 03/31/2010 Post Hearing Comment period closed June 1, 2010 Estimated that a final rule will be issued within 18 months Currently proposed 3 year implementation period to allow industry to change systems, labels, data sheets

9. HAZCOM vs GHS System differences A revision to the criteria for the classification of chemical hazards Changes in label requirements Mandatory use of standardized signal words, pictograms, hazard statements & precautionary statements A required format for Safety Data Sheets (SDS) HAZCOM vs GHS

10. HAZCOM vs GHS New term definitions Changes to employee training requirements Additional OSHA standard modifications to be consistent with GHS Flammable / Combustible liquids Process Safety Management Substance specific health standards

11. HAZCOM VS GHS CLASSIFICAITON OF CHEMICAL HAZARDS

12. HAZCOM vs. GHS Chemical Identification - HCS Manufacturers or importers must assess the hazard of chemicals they produce or import and provide information to their employees about the hazardous chemicals to which they are exposed. Distributors must also transmit the required information to their employees. Chemical Identification - GHS In addition to the requirements of the HCS, GHS requires a harmonized criteria for classifying substances and mixtures according to their health, environmental and physical hazards. Harmonized hazard communication elements, including requirements for labeling and safety data sheets

13. HAZCOM vs. GHS Chemical Identification - HCS The HCS excludes certain hazardous materials covered by other regulatory statutes Pesticides – FIFRA Chemicals substances or mixtures covered by TSCA Food, food additive, color additive, drug, cosmetic or medical / veterinary device covered by Federal Food, drug and Cosmetic Act or the Virus-Serum Toxin Act Chemical Identification - GHS The GHS covers all hazardous chemicals Target audience includes consumers, workers, transport workers and emergency responders There are no complete exemptions from the scope of the GHS for any particular product or chemical type.

14. HAZCOM vs GHS LABELING CHANGES

15. HAZCOM vs GHS Labeling System Changes Hazardous materials are required to be labeled for transport, storage and usage within a facility GHS calls for a harmonization in the labeling process to include standardized symbols and signal words The changes are expected to be applied to the workplace and consumer products Transport application changes are not expected to follow the GHS guidelines The label format is being outlined so that information is in the same location on all labels.

16. HAZCOM vs GHS Information from the Globally Harmonized System (GHS) /Purple Book

17. HAZCOM vs GHS Signal Words / Hazard Pictograms danger Warning

18. HAZCOM vs GHS Signal Words The words “Danger” and “Warning” are being used as signal words to emphasize the hazard and indicate the relative level of the severity of the hazard as assigned by a GHS hazard class and category Danger – For more “severe” hazards Warning – For less “severe” hazards

19. HAZCOM vs GHS Hazard Pictograms Standardized pictograms are intended to convey the hazard through common pictures The pictograms for non-transport will be red bordered with white backgrounds and black symbols For transport, the pictograms will follow the UN Recommendations on the Transport of Dangerous Goods, Model Regulations and will have color as we currently recognize If the transport pictogram is present, there is not a requirement to place the GHS Hazard Pictogram Just like the current requirement for hazard communication on workplace bottles/containers, the GHS label should be affixed

20. HAZCOM vs GHS Examples of GHS Pictograms Information from the Globally Harmonized System (GHS) /Purple Book

21. Hazcom vs. ghs Examples of Transport Pictograms Information from Globally Harmonized System (GHS) /Purple Book

22. HAZCOM vs GHS Hazard & Precautionary Statements

23. HAZCOM vs GHS Hazard & Precautionary Statements Hazard statements have been standardized and given phrases that describe the hazard(s) as found in the hazard classification If there is more than one hazard, then the appropriate hazard statement should be included for all identified hazards

24. HAZCOM vs GHS Pictograms, Signal Words and Hazard Statements

25. HAZCOM vs GHS Safety Data Sheets

26. HAZCOM vs GHS Safety Data Sheets Under GHS, (Material) Safety Data Sheets (SDS) will be in a common format for all materials which require a SDS The format is intended to provide an easier to read document and allow for quicker identification of hazards and dangers of a product The SDS should contain 16 headings and is derived as a combination of document formats from ISO – International Organization of Standardization EU – European Union ANSI – American National Standards Institute

27. HAZCOM vs GHS Safety Data Sheets The minimum recommended information includes: Section 1 – Identification of the substance or mixture and the supplier GHS Product Identifier Recommended uses Supplier details (address, phone number) Emergency phone numbers Section 2 – Hazard identification GHS classification of the substance/mixture GHS label elements (precautionary statements, hazard symbols) Other hazards not classified by GHS (ie dust explosion hazard)

28. HAZCOM vs GHS Safety Data Sheets The minimum recommended information includes: Section 3 – Composition / Ingredients Chemical Identity – common name, synonyms, CAS number, impurities/stablizers, concentrations or concentration ranges Section 4 – First Aid First aid measures based on the different routes of exposure, most important symptoms/effects, indication of immediate medical attention if necessary Section 5 – Firefighting Suitable / unsuitable extinguishing media Special protective equipment and precautions for firefighters

29. HAZCOM vs GHS Safety Data Sheets The minimum recommended information includes: Section 6 – Accidental Release Personal precautions, environmental precautions and containment / cleanup materials and methods Section 7 – Handling and Storage Precautions for safe handling Conditions for safe storage Section 8 - Exposure controls Control parameters, engineering controls and individual protective measures – PPE

30. HAZCOM vs GHS Safety Data Sheets The minimum recommended information includes: Section 9 – Physical / Chemical Properties Properties about the material (e.g. state, appearance, odor, pH, flash point, vapor density, etc) Section 10 – Stability / Reactivity Chemical stability, reaction possibilities, conditions to avoid, incompatibilities, decomposition products Section 11 – Toxicological Information Likely routes of exposure Symptoms associated with physical, chemical and toxicological characteristics Numerical measures of toxicity

31. HAZCOM vs GHS Safety Data Sheets The minimum recommended information includes: Section 12 – Ecological Information Aquatic / Soil Toxicity Persistence and degradability Bioaccumulation potential Section 13 – Disposal Recommended disposal methods Section 14 – Transportation UN Number, Proper Shipping Name, Hazard Class, Packing Group Marine Pollutant (Yes/No) Special Precautions

32. HAZCOM vs GHS Safety Data Sheets The minimum recommended information includes: Section 15 – Regulatory Information Regulatory bodies that govern the chemical / mixtures (e.g. SARA, TCSC, FIFRA) Section 16 – Other Information Preparation and revisions on SDS should be in this section

33. HAZCOM vs GHS Safety Data Sheets With uniform data fields and common terminology, information can easily be found on the sheets Worker understanding of the dangers will also be easier to define

34. HAZCOM vs GHS Terms & Definitions

35. HAZCOM vs GHS Terms / Definitions Common terminology will require all systems (OSHA, EPA, EU, DOT, Canadian, etc) to adopt some changes in order to meet the harmonized goal of the GHS Examples of changes / revisions on terminology for common reference Gas – substance / mixture which at 50oC has a vapor pressure greater than 300kPa Liquid – substance/mixture that is not a gas and has a melting point of 20oC or less at standard pressure Solid – substance/mixture that does not meet the definitions of a liquid or a gas

36. HAZCOM vs GHS Examples of changes in standards for consistency Flammable / Combustible liquids For the purpose of classifying liquids, under the GHS system any liquid that has a flashpoint of not more than 93oC (200oF) is considered a flammable liquid Four categories will be used based on the flash point and boiling point of a liquid 1 = Flash point < 23oC (73.4oF) and initial boiling point < 35oC (95oF) 2 = Flash point < 23oC (73.4oF) and initial boiling point >35oC (95oF) 3 = Flash point > 23oC (73.4oF) and < 60oC (140oF) 4 = Flash point > 60oC (140oF) and < 93oC (200oF) – Current combustible liquid range

37. HAZCOM vs GHS Examples of changes in standards for consistency Process Safety Management For consistency within the GHS program, OSHA is looking at modifications to the PSM program Clear differentiation between the process tanks and storage tanks Changes to the toxicity classifications under GHS will affect the PSM standards

38. HAZCOM vs GHS Training Under the current hazard communication system, employers are required to train employees on the hazard associated with products Right-to-Know stations must be provided GHS does not change this requirement and stresses the importance of training for employees The GHS harmonization with labels / SDS /terminology is intended to make training easier for all

39. HAZCOM vs GHS What can you do to prepare? Final regulatory approval appears to be forth coming with a several year implementation period Companies can begin obtaining the warning labels that are part of the GHS system now for training and understanding Implement usage of the new labels in a phased approach based on the current standards Conduct training sessions with workforce in short “coffee break” times that will introduce the new system

40. HAZCOM vs GHS What can you do to prepare and create harmony? If you prepare MSDS sheets (current term) Begin referring to the document as a Safety Data Sheet (SDS) Re-format your SDS to match the GHS format Provide training on the new format to employees For MSDS sheets you receive Ask suppliers if they can provide in the new format Right-to-Know Stations Update stations with new SDS and advise employees

41. HAZCOM vs GHS What can you do to prepare and create harmony? Display posters / sheets showing the new labeling in the workplace to begin familiarization by employees Show the correlation between current systems and the new system Provide information for employees to ask/answer questions

42. HAZCOM vs GHS GHS Reference A Guide to The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) http://www.osha.gov/dsg/hazcom/ghsguideoct05.pdf

43. HAZCOM vs GHS Questions?