Hazard Communication Right-to-Know Introducing the Global Harmonization Standard and the new revisions to the Hazard Communication/RTK Standard SUNYIT Environmental Health and Safety September 2013

Global Harmonization Standard “Revising OSHA's Hazard Communication standard will improve the quality and consistency of hazard information, making it safer for workers to do their jobs and easier for employers to stay competitive.“ The training looks a little different this year. More changes will be coming with the labels that will start to show up and the new Safety Data Sheets which are replacing Material Safety Data Sheets (MSDSs).

Changes New look to labels. New pictograms on labels. More standardized Safety Data Sheets. Better Safety Data Sheet information. The new standard covers over 43 million workers who produce or handle hazardous chemicals in more than five million workplaces across the country. The modification is expected to prevent over 500 workplace injuries and illnesses and 43 fatalities annually. Once fully implemented it will also: Enhance worker comprehension of hazards, especially for low and limited-literacy workers, reduce confusion in the workplace, facilitate safety training, and result in safer handling and use of chemicals; Provide workers quicker and more efficient access to information on the safety data sheets; Result in cost savings to American businesses of more than $475 million in productivity improvements, fewer safety data sheet and label updates and simpler new hazard communication training; and Reduce trade barriers by harmonizing with systems around the world.

Things that haven’t changed: Chemicals can only cause health effects when they come into contact with your body. Routes of Entry Skin contact (absorption through the skin or damage on contact to skin or eyes) Inhalation Ingestion Injection

Skin Contact Skin irritation or injury Skin absorption (some things are absorbed through the skin)

Some materials are absorbed through the skin: Others irritate or burn the skin:

Eye Contact

Inhalation Inhalation is a very effective way to get high doses of chemicals into the body. You can inhale dusts, vapors, mists or fumes.

Exposure Limits assumes 8 hrs/day and 40 hrs/week generally healthy worker population PEL TLV Threshold Limit Value More responsive to new scientific information There are other exposure limits that may also be used. Permissible Exposure Limit Legally enforceable For both the PEL and TLV, the higher the number, the less toxic a material is, the more you can inhale without injury

Ingestion AMA's Current Procedural Terminology, Revised 1998 Edition. Accidental ingestion can occur in the workplace. Sometimes chemical products are stored near food in poorly controlled areas and workers can make a mistake. More likely, is that workers use the products, fail to clean their hands or change out of protective clothing, and then smoke or eat transferring the chemical to the cigarette, their sandwich etc.  AMA's Current Procedural Terminology, Revised 1998 Edition. 

Injection Less likely in most workplaces, but can occur.

Common Sense: Rules Around Chemicals Respect fire hazard and be prepared to respond to fires, spills, and other emergencies! Understand the hazards associated with the chemicals. Understand the personal protective equipment (PPE) that you need, and all safety procedures. Use the smallest quantity of the least hazardous chemicals possible.

More Common Sense Rules When dealing with dust, use wet methods when you can. Wash after chemical use. Don’t eat or drink around hazardous chemicals. Remove protective clothing and equipment when you have finished the job.

Common Sense Don’t mix different chemicals without authorization. Don’t super-concentrate chemicals that the manufacturer intended to have diluted. More is not necessarily better.

Planning for Chemical Use Engineering Controls Do we need this chemical? Can we isolate the chemical from the people? Work Practice Controls Can we minimize the ways it can impact a worker’s body? Administrative Controls Can we limit exposure to certain areas, time periods? Personal Protective Equipment (PPE) Gloves, goggles, respirators, moon suits, etc. Stress that we only go down the list as necessary and that the PPE is the last line of defense.

How are hazards communicated? Two important tools to supplement supervisor's orientation about hazardous materials in the workplace: Labels Safety Data Sheets

Labels: Standardized Form and Language Symbol – pictogram Signal Word Danger (more significant) Warning Standard hazard statement Discuss “danger” vs “warning” with danger being more serious. The hazard statements are based on specific scientific properties and leave less room for ambiguity.

Point out various sections on the label – e. g Point out various sections on the label – e.g., name of the product, pictogram, precautionary language.

Pictograms Black and white pictures with a red diamond border. Pictures generally give a clue as to hazard. If a number appears, the smaller the number, the greater the hazard! Take a few seconds and discuss NFPA diamond vs GHS numbering! Pictograms add the international flare and combat various language/literacy issues.

Currently Used Labels: HMIS & NFPA Diamond 0 means almost no hazard 4 means extreme danger HMIS Hazardous Materials Identification System NFPA National Fire Protection Association

New GHS Pictograms If there is a number with GHS, the bigger the number the lesser the hazard! Opposite direction from NFPA

Carcinogens cause cancer. Mutagens cause harm to fetuses Carcinogens cause cancer. Mutagens cause harm to fetuses. Reproductive toxins cause problems in pregnancy and/or getting pregnant (men and women). Respiratory Sensitizer means you may have a heightened reaction on second exposure. Target organ is the organ that is most effected. Aspiration toxic means it irritates or harms when you inhale the liquid or solid.

Flammable means vapors burn. Pyrophorics will ignite spontaneously when exposed to air. Organic peroxides can sometimes form explosive compounds by themselves. Self igniters/heaters get warm over time with access to air.

Sensitizers cause more severe second-exposure reactions. Irritants irritate. Sensitizers cause more severe second-exposure reactions. Acute – short term Chronic – long term Example of acute vs chronic – ethyl alcohol short term it that you get relaxed after a few drinks. Chronic drinking causes liver damage.

Gas under pressure can release pressure quickly – causing mechanical hazards and releasing large volumes of gas that can displace air (suffocation potential) or be toxic.

Oxidizers can cause or contribute to fire in other materials.

If you transfer chemicals to another container - it MUST be labeled. Secondary Labeling If you transfer chemicals to another container - it MUST be labeled. Name of product ABC Cleaner General hazard warning information WARNING: May cause eye irritation! Avoid eye contact!

NYS Right-to-Know Law 12 NYCRR Part 820 Notice to Employees posted. MSDS/SDS information must be provided on request. Must be provided within 72 hours of employee request (excluding weekends and holidays). The employee can not be required to work with a chemical for which the information has not been provided after that 72 hours, until the info is provided.

Initial and annual training for employees routinely exposed to toxic substances. The education and training program shall include, but may not be limited to, the following: (a) the location of toxic substances to which the employee may be exposed; (b) the properties of toxic substances to which employees may be exposed; (c) the name or names of the toxic substance, including the generic or chemical name; (d) the trade name of the chemical and any other commonly used name; (e) the acute and chronic effects of exposure at hazardous levels; (f) the symptoms of effects of exposure at hazardous levels; (g) the potential for flammability, explosion and reactivity of such substance; (h) appropriate emergency treatment; (i) proper conditions for safe use and exposure to such toxic substance; (j) procedures for cleanup of leaks and spills of such toxic substance. Go over this briefly!

Goals of training Name two laws that protect an employee’s right-to-know about hazardous materials in the workplace. OSHA’s Hazard Communication Standard NYS’s Right-to-Know Law Name two primary methods used to communicate chemical. Labels Safety Data Sheets Revisit the goals stated at the beginning with answers. You can try to make this interactive.

Name two ways chemicals, in general, can cause injury to the body. There are four “routes of entry” – skin contact, inhalation, ingestion, and injection. Who can help me get more information about the chemicals I work with Where can I find info if a product I am handling can cause an increased risk of pregnancy loss or potentially cause cancer? Info would be on a SDS. Discuss with your healthcare provider. Where can I find the type of gloves I should be using? Info would be on the SDS and often the label.