US Occupational Safety & Health Administration: Article Interpretation

Slides:



Advertisements
Similar presentations
2013 Training Requirements for the Revised OSHA Hazard Communication Standard This presentation (“Employers Hazcom Training Requirements”) summarizes the.
Advertisements

Globally Harmonized System (GHS) Hazard Communication Changes.
DATE  Understand Hazard Communication including revisions to GHS  Label Requirements  Safety Data Sheets.
Hazard Communication Standard Updates O Introduction to Globally Harmonized System (GHS) O Label Elements and Safety Data Sheets (SDS)
1. Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Presentation to RCC Stakeholders - Webinar Session January 14 th, 2014.
 What is GHS?  Who does it effect?  Why is it being implemented?  What will change?  How can employers prepare their employees?  What tools are available.
APMA SAFETY TRAINING OSHA HAZARDOUS COMMUNICATION STANDARD.
UNDERSTANDING THE REQUIREMENTS OF ```````‘s HAZCOM12 What’s changing and how to ensure compliance.
OSHA Has Revised 30 CFR Hazard Communication Standard.
Introduction to the Global Harmonization System, GHS
8/17/20151 Hazard Communication with Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Update.
GHS Training Module 1 Introduction to the Globally Harmonized System of Classification and Labeling of Chemicals.
of classifying and labeling chemicals – Who: Employers – What: Must train employees on label requirements and the new safety data sheets.
Hazcom 2012 – The Right to Understand What is the GHS? The GHS is an acronym for The Globally Harmonized System of Classification and Labeling of Chemicals.
Safety Initiatives Facing Today’s Business January 29, 2013.
Slide 1 Presented by: Insert name MEMIC Safety Management Consultant Hazard Communication Standard and the Globally Harmonized System (GHS) Overview.
S | D | A | O Special Districts Association of Oregon GHS The Globally Harmonized System of Classification and Labeling of Chemicals.
Globally Harmonized System Hazard Communication
OSHA’s Hazard Communication Proposal to Align with Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Maureen Ruskin Director.
American Mushroom Institute OSHA Philadelphia Area Office Alliance General Meeting April 25, 2013.
OSHA Hazard Communication Standard What is Changing? Uniform classification of hazards –Global Harmonization System New Label requirements –Pictograms.
MIOSHA ASBESTOS PROGRAM UPDATE Michael T. Mason March 13, 2014.
Pre-Meeting Notes Remember to review the notes section of the presentation prior to presenting Review GPS Scorecard and Rankings (give some positive recognition.
New labeling requirements. Objectives To train employees on the revised Hazard Communication Standard - known as the Global Harmonization System (GHS)
1 Training Requirements by February 1, 2015 Hazard Communication in Agriculture This training is part of the PESO Program and is also available in Spanish:
1 This training is part of the PESO Program and is also available in Spanish: Spanish - Español Hazard Communication Aligned.
1 Training Requirements by December 1st, 2013 Revised Hazard Communication Rule This training is part of the PESO Program and is also available in Spanish:
Hunt’s Taylor Creek Contractors Training on new Hazard Communication Standard 29 CFR
There is no evaluation associated with this lesson.
HazCom and GHS OSHA created the Hazard Communication Standard in Ensures that employers inform employees about hazardous chemicals.
Hazard Communication Subpart Z Toxic and Hazardous Substances Presented by Betty Dunbar Delaware Department of Labor Office of Occupational Safety.
June Initially developed in 1983 to give employees a “right to know” Required a comprehensive hazard evaluation and communication process Chemical.
MSDS vs. SDS What’s the difference?.
July 25, :00-2:30 PM Hazard Communication 2012: One Year of Implementation.
The Globally Harmonized System Hazard Communication 2012 What Changes You Can Expect.
Hazard Communication Enforcement Society for Chemical Hazard Communication September 27-28, 2005 Jackie Annis, IH Occupational Safety and Health Administration.
November 2013 California State University, Northridge Department of Chemistry and Biochemistry.
Purpose, Scope and Application of the GHS 1. The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is a rational and comprehensive.
1 AGENDA  Hazard Communication: –Upcoming Changes –Pictograms –New Label Format –Signal Word –Safety Data Sheets.
GHS Hazard Communication Revised: 01/26/2016. What is GHS? GHS stands for the Globally Harmonized System of Classification and Labeling of Chemicals.
Compliance with OSHA’s Hazard Communication Standard 2012 HAZCOM 2012 Judy Davidson – UAW IH Program Manager Jean Carron – GM IH Program Manager Judy.
Wellington Health Care Alliance Presents
Herman Jett Area Manager Cal/OSHA Consultation Services for Los Angeles and Orange Counties 1 Centerpointe Drive Suite 150 La Palma, CA
Global Harmonized System or GHS Scott Martino. Albert Einstein.
Scott D. Cole, COSS, CSP What is GHS? UN-developed system for chemical classification and hazard communication through harmonized.
INTRODUCTION TO OSHA Lesson
Hazard Communication Standard Updates
HAZCOM-GHS Training July 2012.
Pesticide Labels & Safety Data Sheets
Welcome to this Chemscape presentation with an update on the changes to Canada’s WHMIS legislation as it transition to adopting the international GHS standards.
Hazard Communications Standard HS-105 (R)
Globally Harmonized System
Science Laboratory Safety Webinar
Update - Transportation of Lithium Batteries
1 – New Label Elements 2 – Safety Data Sheets
Battery Legislation/Regulation US State Actions
Globally Harmonized System (GHS) Employee Required Training By December 1, 2013 Train Employees on the new label elements and the Safety Data Sheet (SDS)
Hazard Communication Update
WHMIS 2015 Refresher Training.
WinnCompanies Globally Harmonized System of Classification and Labeling of Chemicals Training.
On Feb. 11, 2015, the federal Workplace Hazardous Materials Information System (WHMIS) legislation was amended to incorporate standards set by the United.
Hazard Communication.
EMPLOYEE “RIGHT –TO –KNOW” LAW
Safety Data Sheets.
Hazard Communication 2012: One Year of Implementation
For Persons Who Routinely Work With Chemicals
Summary of OSHA Letter Impacts
American Mushroom Institute OSHA Philadelphia Area Office Alliance
[image location: oshafordentistry
What is the GHS? A world-wide approach to defining and classifying hazards, and communicating information on labels and safety data sheets.
Presentation transcript:

US Occupational Safety & Health Administration: Article Interpretation Presentation to the19th Trilateral Battery Working Group Meeting NEMA Dry Battery Section October 2016

OSHA Article vs. Chemical History In December 2015 LabelMaster received a Letter of Interpretation from OSHA saying that lithium and lithium ion batteries were Chemicals not Articles. The impact is that all batteries would be subject to the full OSHA Hazardous Communications Standard. (29 CFR 1910.1200) In early 2016 the PRBA held two meetings with OSHA to try to convince them that their interpretation was a mistake. These meetings did not go well. NEMA was fully involved in these meetings. In June 2016 the PRBA sent a very detailed 9-page letter to OSHA again arguing our position and asking for clarification if OSHA continued to stand by the initial Letter of Interpretation. October 20, 2016 – NEMA Hdqts 2 NEMA – TWG 2016 BUSINESS CONFIDENTIAL

OSHA Article vs. Chemical What is the result of batteries being a “Chemical”? OSHA considers the battery case to be a “container” of chemicals that could expose users to the chemicals if the can is somehow breached during any point in its life span. While the initial Letter of Interpretation was limited to lithium and lithium ion, our conversations with OSHA made it very clear that OSHA interprets all batteries to be chemicals not articles. Battery Manufacturers would have to develop a fully compliant Global Harmonized System (GHS), Safety Date Sheet (SDS) for all of our batteries. These SDS would need all of the appropriate warning icons. October 20, 2016 – NEMA Hdqts 3 NEMA – TWG 2016 BUSINESS CONFIDENTIAL

OSHA Article vs. Chemical Also . . . Batteries would have to be labeled with a Product Identifier, a Signal Word, Hazard Statement, Precautionary Statements, Supplier Identification and the appropriate mandatory pictograms. All employers would have to provide information to workers on the presence and hazard of chemicals in their workplace. All employers would be required to provide effective information and training to all employees on the hazard chemicals found in batteries. This would have to be done before they could work with these chemicals and would have to cover all risks. October 20, 2016 – NEMA Hdqts 4 NEMA – TWG 2016 BUSINESS CONFIDENTIAL

OSHA Article vs. Chemical What do you do right now? Per our request, OSHA has not formally published their December 2015 Letter of Interpretation to LableMaster on their website. OSHA has verbally told us that they would not take any enforcement action until this issue is fully resolved. As of today, we have not seen any enforcement. We wait for a response to our June 2016 letter and then meet with them again to address issues in their response letter. PRBA is looking to start developing fully compliant GHS SDS in 2017 in anticipation of receiving a formal response from OSHA. October 20, 2016 – NEMA Hdqts 5 NEMA – TWG 2016 BUSINESS CONFIDENTIAL

OSHA Article vs. Chemical Sample GHS Compliant Label October 20, 2016 – NEMA Hdqts 6 NEMA – TWG 2016 BUSINESS CONFIDENTIAL

OSHA Article vs. Chemical In addition . . . . The primary battery industry should begin developing GHS SDS for all of our batteries While Japan and the EU clearly believe batteries are Articles and not Chemicals, the US and Canada will very likely continue to disagree with this interpretation If you want to ship to the US or Canada or to OEM’s who ship to the US and Canada, you will need a GHS SDS, your products will have to be labeled and you’ll have to help your customers do employee training. October 20, 2016 – NEMA Hdqts 7 NEMA – TWG 2016 BUSINESS CONFIDENTIAL