Hazard Communication 2012 & Right-To-Know

Summary of 2012 Changes Revised 1994 Haz Com Standard (HCS) Goal is to be consistent with United Nations Globally Harmonized System Terminology Changes: Hazard Determination Hazard Classification Evaluate Classify MSDS SDS

Appendices Information that used to be in definition section was moved to appendices: Appendix A – Health Hazard Criteria Appendix B – Physical Hazard Criteria Appendix C – Allocation of Label Elements Appendix D – Safety Data Sheets

Purpose of Regulation To protect employees from chemical hazards in the workplace NYS PESH Training and Education

Hazardous Chemical Any chemical which is classified as a physical hazard or a health hazard Also includes: Simple asphyxiants Combustible dusts Pyrophoric gases Hazards not otherwise classified

Hazard Classification Hazard Class and Category (Severity), where appropriate Identify and consider full range of available scientific literature and other evidence concerning potential hazards including mixtures Appendix A for Health Hazards Appendix B for Physical Hazards

Appendix B – Physical Hazard

App B - Physical Hazards This table shows the hazard classes and categories OSHA adopted in its final rule. As with health hazards, OSHA tried to maintain the scope of Haz Com 1994 for physical hazards in Haz Com 2012. Therefore, you will notice this list also includes pyrophoric gases and combustible dusts. The definition for pyrophoric gas is contained in paragraph (c) and the label elements are presented in Appendix C. For combustible dust, we are treating as we always have. The definition for this hazard is provided in the Combustible Dust NEP (Directive CPL 03-000-008). Guidance on this hazard is provided using existing documents, including those on OSHA’s webpage. In addition there are a number of voluntary consensus standards (particularly those from NFPA) that address combustible dust. Deana will now talk about the hazard communication program and labels. 8 8 8 8

Explosives/Blasting Agents Old New NYS PESH Training and Education

Flammables Gases, Aerosols, Solids and Liquids Precautions - Sources of ignition Storage Housekeeping Proper use

Comparison of New and Old Flammable Liquid Criteria GHS Flammable and Combustible Liquids Standard (29 CFR 1910.106) Category Flashpoint ºC (°F) Boiling Point ºC (°F) Class Boiling Point ºC (°F) Flammable 1 < 23 (73.4) ≤ 35 (95) Flammable Class IA < 22.8 (73) < 37.8 (100) Flammable 2 > 35 (95) Flammable Class IB ≥ 37.8 (100) Flammable 3 ≥ 23 (73.4) and ≤ 60 (140) Flammable Class IC Combustible Class II ≥ 22.8 (73) and < 37.8 (100) ≥ 37.8 (100) and < 60 (140) Flammable 4 > 60 (140) and ≤93 (199.4) Combustible Class IIIA ≥ 60 (140) and <93.3 (200) None Combustible Class IIIB ≥ 93.3 (200)

Gases Under Pressure Formerly known as “Compressed Gases” Oxygen Acetylene Chlorine Nitrogen NYS PESH Training and Education

Oxidizers Substance which may, generally by providing oxygen, cause or contribute to the combustion of other material more than air does NYS PESH Training and Education

Pyrophorics A solid or liquid which, even in small quantities, is liable to ignite within five minutes after coming into contact with air Pyrophoric gas is a chemical in a gaseous state that will ignite spontaneously in air at a temperature of 130 degrees F (54.4 degrees C) or below NYS PESH Training and Education

Self-Reactive & Self-Heating Self-reactive chemicals are thermally unstable liquid or solid chemicals liable to undergo a strongly exothermic decomposition even without participation of oxygen Self-heating of a substance or mixture is a process where the gradual reaction of that substance or mixture with oxygen (in air) generates heat NYS PESH Training and Education

Chemicals which, in contact with water, emit flammable gases are solid or liquid chemicals which, by interaction with water, are liable to become spontaneously flammable or to give off flammable gases in dangerous quantities Organic peroxides are thermally unstable chemicals, which may undergo exothermic self-accelerating decomposition. In addition, they may have one or more of the following properties: (a) Be liable to explosive decomposition; (b) Burn rapidly; (c) Be sensitive to impact or friction; (d) React dangerously with other substances.

App A - Health Hazards Hazard Class Hazard Category 17 Acute Toxicity 2 3 4 Skin Corrosion/Irritation 1A 1B 1C Serious Eye Damage/ Eye Irritation 2A 2B Respiratory or Skin Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Lactation Specific Target Organ Toxicity (STOT) – Single Exposure STOT – Repeated Exposure Aspiration Simple Asphyxiants Single Category This slide provides a handy table that you may find useful. It contains all of the health hazard classes covered under Hazcom 2012 in the left column, and then provides their corresponding hazard categories in the right column. I would also like to point out that simple asphyxiants has been added to the bottom of this table. It is italicized in the table because Simple asphyxiants is not one of the 10 health hazards addressed in Appendix A. This is because it is not one of the harmonized hazard classes in the GHS. But, since simple asphyxiants are already covered under Hazcom 1994, and OSHA didn’t want to diminish protections, simple asphyxiants have been addressed separately in the final rule, with a definition provided in paragraph (c) and the required label elements provided in Appendix C. 17

Toxicity The ability to cause injury to a living system Neurotoxin Hepatotoxin Nephrotoxin Dermaltoxin Cardiotoxin NYS PESH Training and Education

Routes of Exposure Inhalation Ingestion Absorption Injection NYS PESH Training and Education

Acute vs Chronic Toxicity Acute – effects appear promptly after exposure, usually within 24 hours Chronic – delayed effects following repeated, long duration exposure NYS PESH Training and Education

Dose – Response Concept The effect of a chemical depends upon the amount and duration of exposure A substance could be helpful in small doses (drug remedy) but harmful in larger doses (poison) NYS PESH Training and Education

Acute Toxicity Adverse effects occurring following oral or dermal administration of a single dose of a substance, or multiple doses given within 24 hours, or an inhalation exposure of 4 hours Acute Toxicity – Inhalation:

Toxicity Agent LD50 (mg/kg) Ethanol 10,000 Sodium Chloride 4,000 Morphine Sulfate 900 DDT 100 Nicotine 1.0 Tetrodotoxin 0.10 Botulinus toxin 0.00001 NYS PESH Training and Education

Corrosion vs Irritation Irreversible tissue damage Reversible tissue damage

Sensitizers Respiratory sensitizer – Chemical that will lead to hypersensitivity of the airways following inhalation Skin sensitizer – Chemical that will lead to an allergic response following skin contact

Other Health Hazards Carcinogens – Known, presumed or suspected Germ Cell Mutagens – Cause genetic changes which can be passed onto offspring Reproductive toxins – Adverse effects on sexual function and fertility or development of offspring Specific Target Organ Toxicity (STOT) NYS PESH Training and Education

New Hazards Added Hazard category Signal word Hazard statement   Simple Asphyxiant Warning May displace oxygen and cause rapid suffocation Pictogram No Pictogram Combustible Dust2 May form combustible dust concentrations in air

Hierarchy of Controls Engineering Controls – substitution, elimination, ventilation, enclosure Administrative Controls – work practices and employee rotation Personal Protective Equipment – Last resort because hazard still exists NYS PESH Training and Education

How to Protect Employees Implement Effective Program Evaluate chemical hazards in workplace Transmit information to employees NYS PESH Training and Education

Hazard Communication Program Elements Training Labeling Maintain MSDS Chemical List Written Program HazCom Program NYS PESH Training and Education

Develop Chemical List Evaluate workplace and develop list of hazardous chemical products present Also add to list those hazardous chemicals produced in workplace NYS PESH Training and Education

e) Written Program (1)(i) List of Hazardous Chemicals by Product Identifier referenced on Safety Data Sheet

f) Labels – Extensively Rewritten New detailed provisions in Appendix C (1) Labels on Shipped Containers (i) Product Identifier (ii) Signal Word (iii) Hazard Statement (iv) Pictogram (v) Precautionary Statement(s), and (vi) Name, address and telephone number of manufacturer, importer, or other responsible party

New Label Elements Signal word - Indicate the relative level of severity of hazard and alerts the reader to a potential hazard on the label Danger - used for more severe hazards Warning - used for less severe Hazard statement - Describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard Toxic if inhaled Causes severe burns and eye damage Extremely flammable liquid Pictograms

Pictograms

Precautionary Statements Describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling: Prevention Response Storage Disposal

Work Practice Controls - Wet Methods NYS PESH Training and Education

f) Labels (Cont’d) (2) Manufacturer, importer or distributor shall ensure that labels info is: In accordance with Appendix C Prominently displayed, and In English (3) Manufacturer, importer or distributor shall ensure that signal word, hazard statement, and pictogram is located together on tag, label or mark

Appendix C- Label Allocation

Sample HS85 Label HS85 Warning Batch number: 85L6543 Harmful if swallowed. Wash hands and face thoroughly after handling. Do not eat, drink or smoke when using this product. Dispose of contents/container in accordance with local, state and federal regulations. First aid: If swallowed: Call a doctor if you feel unwell. Rinse mouth. GHS Example Company, 123 Global Circle, Anyville, NY 130XX Emergency Telephone (888) 888-8888 Use the Pointer to show the label elements. A word about emergency telephone numbers. If a company has an emergency telephone number …… If the company has a chemical that may be used… See letter of interpretation dated: October 25, 1986, addressed to Mr. Sioris 43 43 43

Sample Label

f)(6) Workplace Labeling Employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either: (i) The information specified under paragraphs (f)(1)(i) through (v) or (ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical

WARNING: New System CONTRADICTS HMIS System Hazardous Materials Identification System Hazard Scale is OPPOSITE of GHS: Minimal Hazard=0 Slight Hazard=1 Moderate Hazard=2 Serious Hazard=3 Severe Hazard=4 NYS PESH Training and Education

Safety Data Sheets (SDS) Formerly MSDS Obtain SDS for all hazardous chemicals present or produced Obtain from manufacturer, distributor, retailer, or on-line resources Organize SDS so they may be located quickly SDS must be readily accessible to employees during all shifts NYS PESH Training and Education

Safety Data Sheets (SDS) 16-section format that is essentially the same as ANSI Z400.1 and Z129.1 – 2010 1994 standard requires similar information, but allowed any format Uniformity will improve effectiveness of SDS Sections 12-15 will not be enforced by OSHA/PESH (other agency jurisdiction)

NYS PESH Training and Education

Hazard Communication Training Must be provided upon initial assignment and when new chemical hazard is introduced NYS PESH Training and Education

Training Must Include: Summary of the standard and the program Hazardous chemical properties and methods that can be used to detect their presence or release Physical and health hazards associated with exposure Procedures to protect against hazards Spill and leak procedures Location of SDS and written program NYS PESH Training and Education

h) Training Changes (h)(3) Employee training shall include at least: (ii) The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area (iv) The details of the HCP developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the SDS, including the order of information and how employees can obtain and use the appropriate hazard information

Effective Dates (1) Training on new label elements and SDS format by December 1, 2013 (2) Manufacturers, importers, distributors, and employers must comply with modified provisions no later than June 1, 2015, except: (i) After December 1, 2015, distributor shall not ship containers without compliant labels (ii) Employer must update alternate labeling, HCP, and provide additional training for newly identified physical or health hazards no later than June 1, 2016 (3) May comply with previous and/or current standard during transition period

Right-To-Know NYS law requiring that employees be provided with annual training on toxic substances in the workplace Must be provided during working hours, with no loss of pay, and in location convenient to worksite Required to keep records of training NYS PESH Training and Education

Right-To-Know Must conspicuously post sign informing employees of their right to information about toxic substances in the workplace NYS PESH Training and Education