3. Pesticide Education Program
• An international mandate to harmonize labels
was adopted at the United Nations
Conference on the Environment and
Development (UNCED) in 1992 in Brazil:
– A globally-harmonized hazard classification and
compatible labeling system, including material
safety data sheets and easily understandable
symbols, should be available, if feasible, by the
year 2000.
History of GHS
4. Pesticide Education Program
In March 2012, Occupational Safety
and Health Administration (OSHA)
published a final rule to align its
Hazardous Communication
Standards (HCS) regulations with the
Globally Harmonized System (GHS)
of Classification and labeling of
chemicals
5. Pesticide Education Program
The primary goal of GHS is improved
protection of human health and the
environment by providing chemical
users and handlers with enhanced
and consistent information on
chemical hazards.
6. Pesticide Education Program
The GHS is based on major existing
systems for industrial chemicals,
pesticides, consumer chemicals, and
chemicals in transport, but
implementation of the GHS would
require some changes in all existing
systems in order to achieve
harmonization.
7. Pesticide Education Program
However, it is important for growers who
use Federally regulated pesticides to
note that the Environment Protection
Agency (EPA) has NOT yet moved to
amend its pesticide labeling regulations
under the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA) to align with
the GHS.
8. Pesticide Education Program
Under the HazCom 2012, the MSDS
will be replaced with a Safety Data
Sheet (SDS).
Why the switch from MSDS to SDS?
9. Pesticide Education Program
Why the switch from MSDS to SDS?
• Before the HazCom 2012, there were several
acceptable MSDS formats. OSHA’s adoption of
Global Harmonization Standards (GHS)
requires the use of a single format.
• All SDS will have 16 sections that appear in a
specific order.
12. Pesticide Education Program
• MSDS to SDS Format
– MSDS will now be referred to as Safety Data
Sheets (SDS).
– There is now a specified 16-section format that
must be followed.
Changes
13. Pesticide Education Program
• Includes
– Product identifier (Product Name).
– Manufacturer’s or distributor’s name, address and
phone number.
– Emergency phone number.
– Recommended use.
– Restrictions on use.
Section 1
Identification of Substance and Supplier
14. Pesticide Education Program
• Includes:
– All hazards regarding the chemical.
– Required label elements:
• Pictograms.
• Signal Word.
• Hazard Statements.
Section 2
Hazard Identification
16. Pesticide Education Program
• Includes:
– Composition/information on ingredients:
• Common Name.
• CAS number.
• Concentration.
– Information on chemical ingredients.
– Trade secret claims.
Section 3
Composition/Information on Ingredients
17. Pesticide Education Program
• Includes:
– Important symptoms.
– Acute symptoms.
– Delayed symptoms.
– Required treatment based on route of exposure.
Section 4
First Aid Measures
18. Pesticide Education Program
• Includes:
– Suitable extinguishing techniques.
– Equipment needed.
– Chemical hazards from fire.
Section 5
Firefighting Measures
19. Pesticide Education Program
• Includes:
– Emergency procedures.
– Protective equipment.
– Proper methods of containment and cleanup.
Section 6
Accidental Release Measures
20. Pesticide Education Program
• Includes:
– Precautions for safe handling.
– Precautions for safe storage.
– Incompatibilities.
Section 7
Handling and Storage
21. Pesticide Education Program
• Includes:
– OSHA’s Permissible Exposure Limits (PELs).
– Threshold Limit Values (TLVs).
– Appropriate engineering controls.
– Personal Protective Equipment (PPE)
requirements.
Section 8
Precautions to Control Exposure/
Personal Protection
23. Pesticide Education Program
• Includes:
– Stability of chemical.
– Chemical characteristics.
Section 10
Stability and Reactivity
24. Pesticide Education Program
• Includes:
– Routes of exposure.
– Related symptoms.
– Acute effects.
– Chronic effects.
– Numerical measures of toxicity.
• LD50 values and LC50 values.
Section 11
Toxicological Information
25. Pesticide Education Program
OSHA does not regulate sections 12 to
16 since other Agencies (like the EPA)
regulate information in these sections.
26. Pesticide Education Program
• Includes:
– Eco-toxicity.
– Mobility.
• Does it move in air, soil, or water.
– Degradability.
• Is it biodegradable.
– Bioaccumulation.
Section 12
Ecological Information
27. Pesticide Education Program
• Includes:
– Advise to contact local wasted disposal authority for
direction on disposal.
– Information that directs washing liquids should not be
allowed to enter drains.
– Directions for container disposal.
– Recommendations for disposal if recycling is not an
option.
Section 13
Waste Disposal Consideration
29. Pesticide Education Program
For pesticides this is the area where any FIFRA information
would be included, for example:
“Pesticide Registration:
This chemical is a pesticide product registered by the
Environmental Protection Agency and is subject to certain labeling
requirements under federal pesticide law. These requirements
differ from the classification criteria and hazard
information required for safety data sheets, and for workplace
labels of non-pesticide chemicals. Following is the hazard
information as required on the pesticide label:”
Section 15
Regulatory Information
30. Pesticide Education Program
• Includes:
– Department issuing SDS.
– Email address.
– Training necessary.
– Reissue date/reason for reissue.
– General intended use of the product.
Section 16
Other Information
39. Pesticide Education Program
• The definitions of hazard have been changed to
provide specific criteria for classification of health
and physical hazards, as well as classification of
mixtures
• These specific criteria will help to ensure that
evaluations of hazardous effects are consistent
across manufacturers, and that labels and safety
data sheets are more accurate as a result
Hazard Classification
40. Pesticide Education Program
Will the change require that both and MSDS
and an SDS be kept for the same product?
• For compliance with the new OSHA HazCom 2012
regulatory requirements, maintaining both an MSDS
and a SDS for the same chemical is not necessary.
• As the SDS becomes available for individual products,
they will replace the existing MSDS.
• Although there is no requirement to keep the older
MSDS once it is replaced with an SDS, a good
management practice would be to keep an electronic
copy on file, especially if existing stocks of the chemical
were purchased under the older MSDS.
41. Pesticide Education Program
Will the change require that both and MSDS
and an SDS be kept for the same product?
• When the chemical in question is a pesticide
and the content of the MSDS and the SDS
differs, a copy of both documents must be
maintained to ensure compliance with OSHA
HazCom 2012 and FIFRA which regulates
pesticide products.
42. Pesticide Education Program
The differences between EPA’s
current requirements and the GHS
are related to classification criteria,
hazard statements, pictograms, and
signal words.
43. Pesticide Education Program
For example, FIFRA pesticide product
labels may contain the following signal
words: of “Danger-Poison with the skull
and crossbones graphic,” “Warning,” or
“Caution” depending on the toxicity
level of the product, and “Danger” for a
product that may be a potential skin or
eye irritant.
45. Pesticide Education Program
How this may cause a problem for
example is the label of a chemical
that has an oral LD50 of 550 mg/kg
bears the signal word “Caution”
under current FIFRA labeling
practices but would require the
signal word “Warning” under the
GHS Safety Data Sheet format.
46. Pesticide Education Program
For pesticide products, FIFRA labels
approved by EPA pre-empt OSHA’s
label requirements, but not the
requirements for SDS and worker
training (except for certified
applicators and agricultural workers
for whom EPA has training
requirements).
47. Pesticide Education Program
EPA realizes that this may require users
of the SDS that are prepared for
pesticide products to become familiar
with two different systems, at least
until the agencies’ requirements are
harmonized.
48. Pesticide Education Program
As a result, EPA issued guidance in the
April 20, 2012 Federal Register to
manufactures so that when changes
are made to the SDS to meet the OSHA
requirements, the new SDS format will
also be in compliance with the
pesticide regulations under FIFRA.
49. Pesticide Education Program
Will the change require that both and MSDS
and an SDS be kept for the same product?
• When the chemical in question is a pesticide
and the content of the MSDS and the SDS
differs, a copy of both documents must be
maintained to ensure compliance with OSHA
HazCom 2012 and FIFRA which regulates
pesticide products.
51. Pesticide Education Program
HazCom 2012 Compliance
Dates and Deadlines:
• December 1, 2013 –
– Employers must train employees on how to read
GHS formatted labels and SDS’s.
– Changes to labels are probably more substantial,
however, employees need to understand where to
find information on the SDS.
52. Pesticide Education Program
HazCom 2012 Compliance
Dates and Deadlines:
• 2013 – 2015 On an Ongoing Basis –
– Employers should replace existing MSDSs with
new SDSs as they become available.
– For pesticide products, employers must be sure to
determine if there are any differences between
the MSDS and SDS. If differences exist, a copy of
the MSDS must also be maintained to be in
compliance with both HazCom2012 and FIFRA.
53. Pesticide Education Program
HazCom 2012 Compliance
Dates and Deadlines:
• June 1, 2015 – Chemical manufacturers and
distributors should have completed their
reclassification of chemicals and be shipping
GHS formatted SDS and labels with their
shipments.
54. Pesticide Education Program
HazCom 2012 Compliance
Dates and Deadlines:
• December 1, 2015 – Distributors have an
additional 6 months beyond the June 1, 2015
date to pass along manufacturer labels and
SDSs in the older formats. However, beyond
December 1, 2015, all MSDSs and labels in the
U.S. should be in compliance with HazCom
2012 provisions.
55. Pesticide Education Program
HazCom 2012 Compliance
Dates and Deadlines:
• June 1, 2016 –
– Employers should be fully compliant with
HazCom 2012. That includes making any
necessary updates to their HazCom program,
training employees on any newly identified
chemical hazards (identification of new hazards is
likely during the reclassification process chemical
manufacturers undertake), and updating SDS
libraries and secondary labels.
