Pesticide Education Program Globally Harmonized System (GHS) Change from Material Safety Data Sheet (MSDS) to Safety Data Sheet (SDS)

Pesticide Education Program Objectives History of GHS Major Changes Under GHS What Do You Need to Do Step by Step Compliance

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 History of GHS

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

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.

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.

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.

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?

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.

Pesticide Education Program Major Changes Under GHS

Pesticide Education Program MSDS to SDS Format Labeling Requirements/Pictograms Hazard Classification Changes

Pesticide Education Program MSDS to SDS Format – MSDS will now be referred to as Safety Data Sheets – There is now a specified 16-section format that must be followed. Changes

Pesticide Education Program Section 1 Identification of Substance and Supplier

Pesticide Education Program Section 2 Hazard Identification

Pesticide Education Program Section 3 Composition/Information on Ingredients

Pesticide Education Program Section 4 First Aid Measures

Pesticide Education Program Section 5 Firefighting Measures

Pesticide Education Program Section 6 Accidental Release Measures

Pesticide Education Program Section 7 Handling and Storage

Pesticide Education Program Section 8 Precautions to Control Exposure/Personal Protection

Pesticide Education Program Section 9 Physical and Chemical Properties

Pesticide Education Program Section 10 Stability and Reactivity

Pesticide Education Program Section 11 Toxicological Information

Pesticide Education Program Section 12 Ecological Information

Pesticide Education Program Section 13 Waste Disposal Consideration

Pesticide Education Program Section 14 Transportation Information

Pesticide Education Program Section 15 Regulatory Information

Pesticide Education Program Section 16 Other Information

Pesticide Education Program Pictograms

Pesticide Education Program Pictograms Health Hazard – Carcinogen – Respiratory sensitizer – Reproductive toxicity – Target Organ toxicity – Mutagenicity – Aspiration toxicity

Pesticide Education Program Pictogram Flame – Flammables – Self-Reactives – Pyrophorics – Self-Heating – Emits flammable gas – Organic peroxides

Pesticide Education Program Pictograms Exclamation Mark – Skin and eye irritant – Skin sensitizer – Acute toxicity – Narcotic effects – Respiratory tract irritant

Pesticide Education Program Pictograms Gas Cylinder – Gas Under Pressure Flames Over Circle – Oxidizer

Pesticide Education Program Pictograms – Corrosion Corrosives – Skull and Crossbones – Acute Toxicity (Severe)

Pesticide Education Program Pictograms Exploding Bomb – Explosives – Self-Reactive – Organic peroxides

Pesticide Education Program Pictograms Environment – Aquatic Toxicity

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

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 MSDSs. 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.

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.

Pesticide Education Program The differences between EPA’s current requirements and the GHS are related to classification criteria, hazard statements, pictograms, and signal words.

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.

Pesticide Education Program The GHS uses only two signal words, “Danger” and “Warning.”

Pesticide Education Program How this may cause a problem for example is the label of a chemical that has an oral LD 50 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.

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).

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.

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.

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.

Pesticide Education Program HazCom 2012 Compliance Dates and Deadlines: There is a 3 year phase in period through 2016

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.

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 HasCom2012 and FIFRA.

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.

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.

Pesticide Education Program HazCom 2012 Compliance Dates and Deadlines: June 1, 2016 – – Employers should be fully compliant with HazCom 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.

Pesticide Education Program This presentation was created in partnership with the Pesticide Education Program, Penn State Cooperative Extension; and the Pennsylvania Department of Agriculture. For more information on this and other resources, please visit extension.psu.edu/pested Where trade names appear, no discrimination is intended, and no endorsement by Penn State Cooperative Extension is implied. Penn State is committed to affirmative action, equal opportunity, and the diversity of its workforce. © The Pennsylvania State University 2012November 2012