The Hazard Communication Standard (HCS) is based on a simple concept Employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to at work Background

They also need to know what protective measures are available to prevent adverse effects from occurring The HCS is designed to provide employees with the information they need Background

Hazard Communication Standard (a)Purpose (b)Scope (c)Definitions (d)Hazard Classification (e)Written Program (f)Labels (g)Safety Data Sheets (h)Employee Training (i)Trade Secrets (j)Effective Dates Written Program

Four Major Changes Four Major Changes 1.Hazard Classification (changed from hazard determination) 2.Labels 3.Safety Data Sheets (changed from (M)SDS) 4.Information and Training Will affect nearly 40 million workers and 5 million workplaces. 5

Haz Com Revisions Benefits: Improved worker comprehension = appropriate handling and use of chemicals Improved access to information Harmonized classification of health and physical hazards Specific elements for labeling and SDS Reduced burden on overseas exports/imports 6

7 Effective Completion Date RequirementsWho Dec 1, 2013 Train employees on new labels and Safety Data Sheet format Employers June 1, 2015 December 1, 2015 June 1, 2016 Compliance with modified provisions of final rule except: Distributors shall not ship containers labeled unless it is a GHS label Update workplace labeling and HAZCOM program. Additional employee training on newly found physical or health hazards Chemical manufacturers, importers, distributors & employers Employers Transition period May comply with final HAZCOM std. or current std., or both Chemical manufacturers, importers, distributors & employers

A significant portion of the standard pertains only to chemical manufacturers, importers, and distributors Employers who do not produce chemicals only have to focus on establishing a workplace program and communicating information to their workers Chemical Manufacturers

Employers are required to provide information to their employees about the hazardous chemicals to which they are exposed using: A hazard communication program labels and other forms of warnings (material) safety data sheets ((M)SDS) information and training Employers

Employers must develop a written program that covers at least: Labels and other forms of warnings (Material) Safety Data Sheets Employee Information and Training Employer Requirements – Written Program

Employers must develop a written program that covers at least: A list of the hazardous chemicals known to be present at the facility along with (M)SDS’s for each chemical The methods the employer will use to inform employees of the hazards non-routine tasks The hazards of chemicals in unlabeled pipes Written Program

Labels on shipped containers Required Elements on shipped containers  Product identifier  Signal words  Hazard statements  Pictograms  Precautionary statements  Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party A new Appendix C, Allocation of Label Elements, has been provided to indicate the label requirements by hazard class and category Labels are to be updated within 6 months of getting new and significant information about the hazards, or ways to protect those exposed

The employer must ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either: The label information on the shipped container, or Product identifier and words, pictures, symbols, or combination providing general information on the hazards of chemicals Labels must be legible, in English, and prominently displayed on the container or readily available in the work area Workplace Labeling

Labels, Tags, and Markings

The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use by the employee who performs the transfer Container Labeling Exemption for Portable Containers

Example of Simple Label

Example of Complex Label Example of Complex Label

Labels  OSHA is maintaining the current approach to allowing alternatives to labels on each stationary process container  The exception for portable containers under the control of the person who filled them with the chemical remains the same.  Labels on incoming containers are not to be removed or defaced unless immediately replaced by another label  Workplace labels are to be prominently displayed and in English, although other languages are permitted as well

Pictograms

Labels Employers are responsible for maintaining the labels on the containers, including, but not limited to, tanks, totes, drums, and for training their employees on the hazards listed on the labels in the workplace. Labels must continue to be:  legible  contain the pertinent information (such as the hazards and directions for use)  not able to be defaced, (i.e., fade, get washed off,) or removed in any way

(Material) Safety Data Sheets ((M)SDS) are one of the most important tools available to employers for providing information, and protection to workers from hazardous chemicals which are used in the workplace. Safety Data Sheets (SDS)

 Identifies chemicals by name  Tells potential harm and how chemicals will enter the body (Inhalation, ingestion, and/or skin absorption)  Explains signs and symptoms of exposures  Explains emergency procedures

Safety Data Sheets (SDS)  The GHS uses a specified order of information, as well as title descriptions, on the 16-section safety data sheet.  Health, physical and environmental hazard criteria for substances and for classification of mixtures.  Consistent with voluntary industry consensus standards, such as ANSI.  Should improve comprehensibility and issues regarding accuracy of information.

Safety Data Sheet Format 1.Identification of the substance or mixture and of the supplier 2. Hazards identification 3.Composition/informatio n on ingredients 4. First-aid measures 5. Fire-fighting measures 6.Accidental release measures 7. Handling and storage 8.Exposure controls/personal protection 9.Physical and chemical properties 10. Stability and reactivity 11. Toxicological information 12.Ecological information 13.Disposal considerations 14.Transport information 15.Regulatory information 16.Other information, including date of preparation or last revision

Safety Data Sheets (SDS)  SDS in the workplace for each hazardous chemical  Readily accessible during each work shift to employees when they are in their work area(s)

Employers must provide employees information and training on hazardous chemicals in their work area: At the time of their initial assignment Whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area Training may cover categories of hazards Employee Information and Training

Employee Training  OSHA standard covered  Operations in their work area where chemical is used  Pictograms  Location of program, list of chemical, and SDS  Detection of chemical  Hazards of chemical  Protection measures  Emergency procedures  Labeling system used

Employee Training Although this paragraph remains essentially the same, updates include  Training to include label elements and new safety data sheet format - by December 1, 2013  Training to reflect any new hazards identified in the workplace - by June 1, 2016 Training – prescribed label elements and order of information on data sheets facilitate training/comprehensibility.

Temporary Employees  Worksite Specific HazCom Training  Chemicals in use  Methods of detection and prevention  Emergency procedures  Written HazCom Program  Generic HazCom Training  How to read SDS  Labeling requirements  Pictograms  Elements of HazCom Standard  SDS maintenance  Workplace labeling