Hazard Communication and the Globally Harmonized System (GHS)

Goals for this session… Address common hazard communication violations… Understand major elements of hazard communication & global harmonization Answer your questions

Have you recently checked all the work and storage areas to ensure you have a comprehensive list of all of the chemicals at your site, including products brought to your site by contractors?

Does your hazard communication program identify the method you will use to inform employees of the hazards of non-routine tasks and procedures for sharing information with employees other than your own?

Have you checked this month to ensure all secondary containers are labeled with an appropriate hazard warning?

Do you have the ability to send a MSDS for a product [nox-rust (19)] to the hospital with an injured employee?

Do you have evidence your employees have been trained on the health hazards of all of the chemicals they can smell at work?

Hazardous chemical any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified OSHA previously used “chemical” to indicate both substances and mixtures. We will continue to use this term in the same manner. Similarly, the term “hazardous chemical” will also be used as a shorthand reference to both substances and mixtures after they have been classified as hazardous or determined to be a hazard not otherwise classified. Hazardous chemical means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified. 8 8 8 8

Products and chemicals not covered Hazardous waste covered RCRA (EPA). Hazardous substances when it is the focus of remedial or removal action conducted under CERCLA (EPA) Tobacco or tobacco products. Wood or wood products treated wood and wood that is cut generating dust are not exempt Articles - not a fluid or particle in its end use that does not release hazardous chemicals and does not pose a health risk Food or alcohol sold in retail for personal consumption. Any drug defined by the Federal Food, Drug, and Cosmetic Act. Cosmetics for personal use. Any consumer product covered by the CPSC. Nuisance particulates that do not pose a physical or health hazard. Ionizing and nonionizing radiation. Biological hazards

Consumer Products defined as such under the CP Safety Act used as intended by the manufacturer used with the same frequency and duration of a typical consumer. Windex – Isopropanol & Ethyleneglycol Monohexylether Flash point - 130°F sprayed onto glass for cleaning Is the frequency and duration of exposure is greater than a normal consumer?

No change to basic hazard communication program Management responsibility for program Develop list of hazardous chemicals Label hazardous chemical containers Manage Safety Data Sheets Procedures for training exposed employees Address the hazards of non-routine tasks Procedures for Multi-employer workplaces

Currently chemicals labeled with… Chemical identity Appropriate hazard warnings Name and address of the responsible party 1910.1200(f) Chemical manufacturers and importers must convey the hazard information to downstream employers by means of labels on containers and Material Safety Data Sheets (MSDSs). Language used on the warning label does not have to be identical to that on the MSDS. Chemical manufacturers, importers, and distributors must be sure that containers of hazardous chemicals leaving the workplace are labeled, tagged, or marked with: - the identity of the chemical, - appropriate hazard warnings, and - the name and address of the chemical manufacturer, importer, or other responsible party Consumer products having labels meeting requirements of the Consumer Product Safety Act do not have to have additional labeling under the HazCom Standard. Various other chemical products (for example, pesticides, foods, drugs, cosmetics, beverage alcohols) that are subject to labeling laws administered by other Federal agencies are also exempt from the labeling requirements of the HazCom Standard.

The one, one, one rule. When a hazardous chemical is transferred into one container for the immediate use (one shift) by one employee, then the container does not have to be labeled. Any residual in the container must be immediately recycled or treated as waste.

Safety Data Sheets If SDS has been received for a hazardous chemical, employer must contact the supplier, manufacturer, or importer to obtain one and maintain a record of the contact One MSDS may apply to multiple complex mixtures having similar contents and hazards. For information regarding the preparation of MSDSs, see ANSI Z400.1, Hazardous Industrial Chemicals – Material Safety Data Sheets – Preparation.

Safety Data Sheet Accessible during each work shift. Must be in English Electronic access and alternatives to paper are permitted as long as barriers to access are not created.

Hazard Communication Training At the time of initial assignment Whenever a new hazard is introduced in the work area 1910.1200(h) Training is not satisfied solely by giving the employee the data sheets to read. An employer's training program is to be a forum for explaining to employees not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program. This can be accomplished in many ways (audiovisuals, classroom instruction, interactive video), and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them. Training must be carried out in a language that is comprehensible to the employees. Training need not be conducted on each specific chemical found in the workplace, but may be conducted by categories of hazard (e.g., carcinogens, sensitizers, acutely toxic agents, irritants, flammables) that are or may be encountered by an employee during the course of his duties. Employees who have been previously trained by another employer, union, or other entity, do not have to be retrained if the previous training is sufficient to meet the standard’s training requirements for the current work being performed. However, employees must have information about where to find MSDSs in the workplace, who in the company is responsible for the HazCom program, and where to get copies.

Employee information The requirements of the standard. Operations in their work area where hazardous chemicals are present. The location and availability of the written program, hazardous chemical list, and material safety data sheets.

Employee training Methods and observations used to detect a release of a hazardous chemical (monitoring, odor, visual appearance) The physical and health hazards of chemicals in the work area. The measures employees can take to protect themselves (specific procedures, work practices, emergency procedures, and ppe) The details of the hazard communication program (labeling, SDS’s, and how to obtain and use the information.

Standard for a Globally Harmonized System of Classification and Labeling of Chemicals

Development of Final Rule NPRM Published in the Federal Register on September 30, 2009 (74 FR 50280- 50549). The final rule was published in the Federal Register on March 26, 2012 and became effective on May 25, 2012.

Why GHS? Uniform information to communicate chemical hazards for international trade 50,000 chronic illnesses in 1992 from occupational exposure to chemicals Could prevent 43 fatalities annually

In hazard communication 2012… Hazard classification: Provides specific criteria for classification of health and physical hazards Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal words, pictogram, and hazard statement for each hazard class and category. Safety Data Sheets: Will now have a specified 16-section format. Information and training: The GHS requires workers be trained to understand the new labels and safety data sheets.

Organization of the Final Rule Purpose Safety Data Sheets Scope and Application Employee Information and Training Definitions Trade Secrets Hazard Classification Effective Dates Written Hazard Communication Program Appendices A–F Labels and Other Forms of Warning

Appendices Appendix A, Health Hazard Criteria (Mandatory) (NEW) Appendix B, Physical Hazard Criteria (Mandatory) (NEW) Appendix C, Allocation of Label Elements (Mandatory) (NEW) Appendix D, Safety Data Sheets (Mandatory) (NEW) Appendix E, Definition of “Trade Secret” (Mandatory) Appendix F, Guidance for Hazard Classifications re: Carcinogenicity (Non-Mandatory) (NEW)

Effective Completion Date Important Dates Effective Completion Date Requirement(s) Who   December 1, 2013 Train employees on the new label elements and SDS format. Employers June 1, 2015 Comply with all modified provisions of this final rule, except distributor extension Chemical manufacturers, importers, distributors and employers December 1, 2015 Distributors may ship products labeled by manufacturers under the old system until December 1, 2015. June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Transition Period Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors and employers

Hazard Classification Chemical manufacturers and importers must classify each chemical they produce or import: Determine the appropriate hazard classes and associated hazard categories Base this on an evaluation of the full range of available data/evidence on the chemical Use Appendix A for health hazard criteria and Appendix B for physical hazard criteria This slide provides the major steps in hazard classification: Chemical manufacturers and importers must classify each chemical they produce or import: Determine the appropriate hazard classes and associated hazard categories Base this on an evaluation of the full range of available data/evidence on the chemical (no testing is required) Use Appendix A for health hazard criteria and Appendix B for physical hazard criteria The introduction to Appendix A provides the general approach to classification, including bridging principles ( which is the approach used to determine classification of mixtures) 26 26 26 26

10 health hazard categories and 16 physical hazard categories.

Health Hazard Classifications Hazard Category Acute Toxicity 1 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 STOT - Specific Target Organ Toxicity 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.

Physical hazard classification 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. 29 29 29 29

Training Train employees on the new label elements and SDS format by December 1 , 2013. Provide additional training for any newly identified physical or health hazards by June 1, 2016.

Labels Pictograms signal words hazard and precautionar y statements the product identifier supplier identification.

Other hazards which do not result in classification Combustible dusts OSHA includes dusts under its definition for hazardous chemicals, requiring that employers account for them on safety data sheets and in worker training. signal word “warning” hazard statement “may form combustible dust concentrations in air”

No more combustible liquids? Flammable liquids category 1, 2, 3 & 4 No longer use 100 F – 23 C or 95 F

16-Section Safety Data Sheet Identification of the substance or mixture and of the supplier Stability and reactivity Toxicological Hazard(s) identification Ecological information (non mandatory) Composition/information on ingredients Disposal considerations (non mandatory) First aid measures Firefighting measures Transport information (non mandatory) Accidental release measures Regulatory information (non mandatory) Handling and storage Exposure controls/personal protection Other information including information on preparation and revision of the SDS Physical and chemical properties

Appendix D Specifies the minimum information to be included in each of the 16 sections. Two revisions in the final rule: ACGIH TLVs continue to be required on the SDS. Information regarding carcinogenicity classifications by IARC and NTP also continue to be required.

To do list… For Employers Review current hazard communication program and update yours to meet 2012 requirements Training on the label elements Training on new SDS format Start obtaining the updated SDSs For Manufacturers Start classification of products, develop new labels, update safety data sheets, help save lives or prevent disease.

A Guide to The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) http://www.osha.gov/dsg/hazcom/ghs.html