GHS Changes to Hazard Communication: Key Updates and Considerations
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The June 1, 2015 GHS Compliance deadline introduces some changes to hazard communication sheets (SDSs) and labels. This presentation outlines the changes to hazard communication you should expect as well as your responsibilities.
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GHS Changes to Hazard Communication: Key Updates and Considerations
- 1. GHS Changes to Hazard Communication:
- 3. Changes Will We Cover Differences between MSDS & GHS SDS New Label Format Additional Hazardous Chemicals Categories Potential Points of Confusion
- 4. The GHS replaces MSDS with new Safety Data Sheets (SDS)
- 5. GHS Safety Data Sheet Hazard Communication Standard of SDS had 9 sections New GHS has 16 specific sections Consistent with ANSI format, familiar to many employees Section 2 delivers information up-front Some Sections are not enforced by OSHA because they are enforced by other regulatory bodies
- 6. The 16 SDS Sections Section 1. Chemical Product & Company Information Section 2. Hazards Identification Section 3. Composition/Information on Ingredients 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 10. Stability and Reactivity Section 11. Toxicological Information Section 12. Ecological Information* Section 13. Disposal Considerations* * Not Enforced by OSHA Section 14. Transport Information* Section 15. Regulatory Information* Section 16. Other Information
- 7. The GHS also updates labels
- 8. Label Elements 1) Product Identifier 2) Precautionary Statements 3) Hazard Statements 4) Signal Word 5) Hazard Pictogram Red borders, black symbol 6) Supplementary info
- 9. Let’s take a closer look at that label…
- 11. The GHS adds new chemical categories
- 12. Additional Hazardous Chemical Categories 1. Pyrophoric gases 2. Simple Asphyxiants 3. Combustible Dusts Now Required on your SDS
- 13. Potential Points of Confusion during the GHS Transition
- 14. Points of Confusion: Who is Responsible for Updating your MSDS? NFPA Codes on HazCom Labels…
- 15. Updating MSDS: Whose Responsibility is it?
- 16. Updating MSDSs If you are a manufacturer, distributor or importer you must re-author your SDSs It is the responsibility of your supplier to supply you with the most up-to-date MSDSs or SDSs they have authored
- 17. Two exceptions: 1. If you have not recently purchased an item from your supplier… It is your responsibility to check in with them for the most updated version. 2. If you are shipping a finished product internationally… It is your responsibility, not your domestic supplier’s, to author the country-specific GHS compliant SDS
- 18. GHS Implementation Your Responsibilities 1. Re-Classify your Chemicals 2. Re-author your SDSs 3. Generate GHS-compliant Labels 4. Train your Employees
- 19. Hazards Classification GHS Uses 3 Hazard Groups Health Hazards - Dangers to human health -10 Health Hazards Physical Hazards - Damage to the body - 16 Physical Hazards Environmental Hazards - Not under OSHA jurisdiction - Danger to environment - 3 Environmental Hazards
- 20. Hazard Group Different types of hazards e.g. ‘Gases under pressure’ = class in Physical Hazards Class Category Health, Physical or Environmental Hazard Statement Subsections of classes Assigned numbers/letters Category 1 = most hazardous Standardized statement Describes hazard category
- 22. Best to use the two-tiered approach: 1) Have the most accurate raw chemical data about your materials 2) Reference and compare multiple regulatory resources before making any final determinations
- 23. Classification: Reliability The key here is balance - not so many as SDS takes too long to author, but enough to classify with confidence Consult 3 to 5 trustworthy sources Use those same sources each time Recommended: CLP, ECOTOX, RTECS, Sigma MSDS, HSNO CCID
- 25. Vendor Communication The GHS Implementation makes communicating with your vendors essential and urgent But obtaining chemical info from vendors can be challenging Goal is to avoid unrealistic conservative classifications
- 26. Risk Management
- 27. Risk Management Technique 1: Ensure SDS Accessibility Centralize documents – single digital database Tags and other metadata to make queries/searches easier Accessibility from mobile devices/tablets/laptops
- 28. Risk Management Technique 2: Ensure Fastest Possible SDS Retrieval Ease of user interface and searching Respond to emergencies Mobile App for fast retrieval
- 30. Most businesses are turning to SDS Authoring Software to get them through the GHS transition without the stress of deadlines, loss of productivity, and interruptions to other EH&S reporting obligations.
- 31. SDS Authoring Software from ERA Environmental Management Solutions is the most accurate, cost effective, and fast solution available.
- 32. Twenty years providing solutions for chemical compliance. Award-winning team and award-winning software. Exclusive partnerships with major chemical & coating manufacturers to get superior data (AkzoNobel, Sherwin Williams, Du Pont, and many more).
- 33. Want to learn more about the risks the GHS presents to your business? Download your Free Guide: Business Risks and Opportunities Associated with the GHS Transition
- 34. Learn more: www.era-environmental.com Email us: info@era-ehs.com Phone us: 1-866-493-6409 Connect with us: @ERAenvironment
- 35. Thank you Any questions? Email Us at: online@era-ehs.com
Editor's Notes
- Make title slide
- Im going to talk about Safety data sheets and labels, as both have undergone some re-formatting. Once a hazard is classified, you must communicate the corresponding signal word, hazard statements, precautionary statements and pictograms on the label and Safety Data Sheet (SDS). Here are the 16 sections of the new SDS. Section 2, Hazard Identification, is the most important section, containing classification information as well as information that is repeated on the GHS label. As we mentioned by June 2015, all manufacturers and distributors must be using GHS compliant Safety Data Sheets Important: End users of the chemicals do not have to proactively search and replace their MSDSs with SDSs. An end user would need to have the most up to date SDS or MSDS on their floors. However, if you are in any way responsible for authoring SDS or labels for chemical containers (including secondary chemical containers) you will need to start replacing your MSDSs with SDS. Most manufacturers are investing in a GHS SDS authoring system to handle this difficult task for them to ensure they don’t lose money or make mistakes during the GHS implementation.
- Highlighted are the new section on a GHS compliant SDS Again, section 2 is where most of the information is delivered Section 2 is also almost identical to the GHS Label elements Im going to talk about Safety data sheets and labels, as both have undergone some re-formatting. Once a hazard is classified, you must communicate the corresponding signal word, hazard statements, precautionary statements and pictograms on the label and Safety Data Sheet (SDS). Here are the 16 sections of the new SDS. Section 2, Hazard Identification, is the most important section, containing classification information as well as information that is repeated on the GHS label. As we mentioned by June 2015, all manufacturers and distributors must be using GHS compliant Safety Data Sheets Important: End users of the chemicals do not have to proactively search and replace their MSDSs with SDSs. An end user would need to have the most up to date SDS or MSDS on their floors. However, if you are in any way responsible for authoring SDS or labels for chemical containers (including secondary chemical containers) you will need to start replacing your MSDSs with SDS. Most manufacturers are investing in a GHS SDS authoring system to handle this difficult task for them to ensure they don’t lose money or make mistakes during the GHS implementation.
- Most drastic changes happen to the label Pictograms Pictograms are the standardized symbols used to quickly give material handlers a picture of the type of hazards the material presents. Many GHS pictograms will be familiar to North American consumers, as many of them have remained the same from the U.S. HazCom regulations. GHS pictograms: Are always framed within a red square frame set on point . The image itself is always a black symbol on a white background. This means that some manufacturers will need to upgrade their systems to print color labels or start using pre-printed labels. Coming up shortly are the GHS pictograms that can be featured on a label along with the hazards each one is associated with. Supplementary Information This section is not mandatory but if included Supplementary information should include: Additional instructions for handling the material that aren’t covered by the GHS precautionary statements. Hazards not otherwise classified (HNOC). (Some chemical hazards are not classified by the GHS guidelines, but should still be communicated in labels and SDSs. ERA actually produced a guide to GHS classifications and categories for more information on HNOCs.) This section must also identify the percentage of ingredient(s) of unknown acute toxicity when it is present in a concentration of ≥1% open loop to nfpa label issue
- Here is a snippet of an OSHA sample label
- The second important point I wanted to make is that the chemicals you see here have been added to the hazardous chemical; list In the revised Hazard Communication Standard (HCS), OSHA has added pyrophoric gases, simple asphyxiants and combustible dust to the definition of "hazardous chemical". This means All three must be addressed both on container labels and SDSs 1 = danger 2,3 = warning
- I will now Pass you over to Sarah Sajedi, co founder and CTO of ERA environmental She will be discussing the importance of proper classification and how to ensure accuracy and reliability in the process. We will walk you through our Sulfur case study to show you exactly what to look out for.
- process flow chart using example of chemical With June 2015 less than a year away, manufacturers and distributors are strongly encouraged to begin the process of reclassifying their hazardous chemicals in order to update their label and SDs. Let’s review the basics behind GHS Hazard Classification. More details can be found in ERA’s guide to GHS Hazard Classification that can be found on our blog. Where can they get this? Can we email them the landing page?. When you have a product, you must go through the classification steps. First, the GHS uses three major hazard groups: Health Hazards, Physical Hazards and Environmental Hazards -These aren’t required by OSHA. Health hazards present dangers to human health (i.e. breathing or vision) while physical hazards cause damage to the body (like skin corrosion). each hazard group has hazard classes THAT describe the different types of hazards. For example, Gases under Pressure is an example of a class in the physical hazards group. There are 16 physical hazard classes and 10 health hazard classes: each hazard class is then further divided according to different categories. For example, Self-Reactive Chemicals have 7 categories. Each category has rules or criteria to determine what chemicals are assigned to that category. Categories are assigned numbers (or letters) and category 1 (or A) is the most hazardous. For each category of a class, a standardized statement, called a hazard statement, is used to describe the hazard. For example, the hazard statement for chemicals which meet the criteria for the class Self-heating substances and mixtures, Category 1 is Self-heating; may catch fire. This hazard statement would appear both on the label and on the SDS. Note that To classify your mixtures you should use available testing data for the mixture itself along with the GHS classification guidelines. An exception to this is if your mixture is a carcinogen, a mutagen, or a reproductive toxin where classification may be based on the strength of evidence and modified on a case-by-case basis
- break it out
- break it out
- break it out
- The GHS Implementation best practises touch on two things, ensuring accurate data and managing risk The best way to guarantee SDS Accuracy is by automating your vendor communication It oftens seems that environmental information needs to be wrestled out of the hands of a supplier. Most suppliers are reluctant to share their specific chemical information for a number of reasons including the risk it might give their competitors an advantage, and the perception that attaining this information is costly and time consuming. When a supplier is asked to provide additional information to their end-users, it requires time, which in the absence of an automated information system can be significant, especially for chemical vendors with many materials and products. This creates a constant back and forth struggle between the supplier and the vendor in which one tries to get more information while the other is tries to pay for the cost in attaining and communicating it.
- The GHS Implementation best practises touch on two things, ensuring accurate data and managing risk The best way to guarantee SDS Accuracy is by automating your vendor communication It oftens seems that environmental information needs to be wrestled out of the hands of a supplier. Most suppliers are reluctant to share their specific chemical information for a number of reasons including the risk it might give their competitors an advantage, and the perception that attaining this information is costly and time consuming. When a supplier is asked to provide additional information to their end-users, it requires time, which in the absence of an automated information system can be significant, especially for chemical vendors with many materials and products. This creates a constant back and forth struggle between the supplier and the vendor in which one tries to get more information while the other is tries to pay for the cost in attaining and communicating it.
- the GHS practises also ties heavily into Risk management. According to industry research from Accenture, financial institutions are beginning to implement a single risk management “architectural point” for their global operations. One of the primary examples of EH&S being on the forefront of risk management is the 2015 North American adoption of the Globally Harmonized System (GHS). The GHS transition is taking place on an international level, and is causing regulatory agencies around the world to adjust their Hazard Communication standards. Businesses will need to start updating their chemical labels and authoring them to compliance with the GHS-style SDSs, which are more comprehensive than MSDSs. This will require assessing new tools and options, re-evaluating current processes, and contacting your chemical suppliers to ensure all their data is up to date with new regulations. All of these can be considered risk management strategies centralized in your EH&S department. As your business adopts the GHS guidelines, it will be faced with a great deal of options and each of them carries a certain amount of risk and reward. The core of GHS is to improve the way hazardous information is received in a way that ensure workers understand how to deal with hazardous chemicals. Transitioning towards a GHS compliant workplace will help create a safer work environment for employees. This directly translates into an improved corporate image and a reduction in hazard-related risk management. This makes the GHS transition the ideal opportunity to invest in a tool that will assess and mitigate associated risks and improve overall EH&S performance. A safer workplace means safer employees, which puts customers at ease and creates a trust-worthy image for your company. Everybody wins.
- the GHS practises also ties heavily into Risk management. According to industry research from Accenture, financial institutions are beginning to implement a single risk management “architectural point” for their global operations. One of the primary examples of EH&S being on the forefront of risk management is the 2015 North American adoption of the Globally Harmonized System (GHS). The GHS transition is taking place on an international level, and is causing regulatory agencies around the world to adjust their Hazard Communication standards. Businesses will need to start updating their chemical labels and authoring them to compliance with the GHS-style SDSs, which are more comprehensive than MSDSs. This will require assessing new tools and options, re-evaluating current processes, and contacting your chemical suppliers to ensure all their data is up to date with new regulations. All of these can be considered risk management strategies centralized in your EH&S department. As your business adopts the GHS guidelines, it will be faced with a great deal of options and each of them carries a certain amount of risk and reward. The core of GHS is to improve the way hazardous information is received in a way that ensure workers understand how to deal with hazardous chemicals. Transitioning towards a GHS compliant workplace will help create a safer work environment for employees. This directly translates into an improved corporate image and a reduction in hazard-related risk management. This makes the GHS transition the ideal opportunity to invest in a tool that will assess and mitigate associated risks and improve overall EH&S performance. A safer workplace means safer employees, which puts customers at ease and creates a trust-worthy image for your company. Everybody wins.
- the GHS practises also ties heavily into Risk management. According to industry research from Accenture, financial institutions are beginning to implement a single risk management “architectural point” for their global operations. One of the primary examples of EH&S being on the forefront of risk management is the 2015 North American adoption of the Globally Harmonized System (GHS). The GHS transition is taking place on an international level, and is causing regulatory agencies around the world to adjust their Hazard Communication standards. Businesses will need to start updating their chemical labels and authoring them to compliance with the GHS-style SDSs, which are more comprehensive than MSDSs. This will require assessing new tools and options, re-evaluating current processes, and contacting your chemical suppliers to ensure all their data is up to date with new regulations. All of these can be considered risk management strategies centralized in your EH&S department. As your business adopts the GHS guidelines, it will be faced with a great deal of options and each of them carries a certain amount of risk and reward. The core of GHS is to improve the way hazardous information is received in a way that ensure workers understand how to deal with hazardous chemicals. Transitioning towards a GHS compliant workplace will help create a safer work environment for employees. This directly translates into an improved corporate image and a reduction in hazard-related risk management. This makes the GHS transition the ideal opportunity to invest in a tool that will assess and mitigate associated risks and improve overall EH&S performance. A safer workplace means safer employees, which puts customers at ease and creates a trust-worthy image for your company. Everybody wins.
- Transitioning towards a GHS compliant workplace will help create a safer work environment for employees. This directly translates into an improved corporate image and a reduction in hazard-related risk management. This makes the GHS transition the ideal opportunity to invest in a tool that will assess and mitigate associated risks and improve overall EH&S performance. A safer workplace means safer employees, which puts customers at ease and creates a trust-worthy image for your company. Everybody wins. Sending you a follow up email next week you can expect to find the slides of this presentation as well as the recording. We will also be sneding you some materials on SDS Authoring and Classification