Hazard Communication 2013 OSHA 29 CFR 1910.1200

Benefits of adopting the ghs Increase the quality and consistency of information Reduce confusion – Increase comprehension of hazards Help address literacy problems

Notable Changes Labels are more defined and will now require: Product identifier Pictogram Signal word Hazard statement(s) Precautionary statement(s) Name, address, and phone number Safety Data Sheet (not Material Safety Data Sheet) Uses a 16 section format

Organization of Standard Purpose g) Safety Data Sheets * b) Scope and Application h) Employee Information and Training c) Definitions * i) Trade Secrets e) Written Hazard Communication j) Effective Dates * f) Labels and Other Forms of Warning * Appendices A-F

pURPOSE All hazards to be CLASSIFIED not Evaluated "Classification" means to identify the relevant data regarding the hazards of a chemical; review those data to ascertain the hazards associated with the chemical; and decide whether the chemical will be classified as hazardous according to the definition of hazardous chemical in this section.  In addition, classification for health and physical hazards includes the determination of the degree of hazard, where appropriate, by comparing the data with the criteria for health and physical hazards. "Hazard class" means the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute toxicity.

b) Scope and Application All chemicals known to be present are covered. Practical accommodations for special situations Address interface with other Federal laws.

c) Definitions Physical hazard definitions removed and placed in new Appendix B Deleted terms: flashpoint, hazard warning, material safety data sheets. Some definitions were revised to be consistent with the GHS. New definitions added for classification. Signal Word - means a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label.  The signal words used in this section are "danger" and "warning."  "Danger" is used for the more severe hazards, while “Warning" is used for the less severe.

d) Hazard Classification Chemical manufacturers and importers shall evaluate chemicals produced in their workplaces or imported by them to classify the chemicals in accordance with this section.  For each chemical, the chemical manufacturer or importer shall determine the hazard classes, and where appropriate, the category of each class that apply to the chemical being classified.  Employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer or importer for the chemical to satisfy this requirement.

e) Written hazard communication program Employers must have a written program describing how the rule will be implemented, including a list of hazardous chemicals, methods for informing employees about non-routine tasks. Employers must make sure the program is current when the new provisions are implemented (e.g., list of hazardous chemicals may have to be updated).

f) Labels and other forms of warning Shipped containers to be labeled with product identifier; signal word; hazard statement(s); pictograms; precautionary statements; and responsible party. Specifies information by hazard class and category Appendix “C” is a cookbook approach for labeling.

Label Requirements – shipping containers Product identifier Signal word Hazard statement(s) Pictogram(s) Precautionary statement(s) Name, address, and phone number of the responsible party.

Pictograms FLAME OVER CIRCLE HEALTH HAZARD GAS CYLINDER FLAME CORROSION ENVIRONMENT EXCLAMATION MARK EXPLODING BOMB SKULL & CROSSBONES The final rule requires containers shipped six months after the information is available to be labeled correctly.

Flame over Circle Oxidizers Used as rocket fuel in space No ignition source (flame is necessary) Mixing concentrated hydrogen peroxide with an organic material, in the presence of a catalyst will react on its own, causing a very hot flame. Bread with drops of peroxide + leather = hot flame Class Rating Hazard Description Class 1 An oxidizing material whose primary hazard is that it may increase the burning rate of combustible material with which it comes in contact. Class 2 An oxidizing material that will moderately increase the burning rate or which may cause spontaneous ignition of combustible material with which it comes in contact. Class 3 An oxidizing material that will cause a severe increase in the burning rate of combustible material with which it comes in contact or which will undergo vigorous self-sustained decomposition when catalyzed or exposed to heat. Class 4 An oxidizing material that can undergo an explosive reaction when catalyzed or exposed to heat, shock or friction. TABLE 3 - Oxidizing Materials (as Classified by the NFPA) Class Rating Examples Class 1 aluminum nitrate potassium dichromate ammonium persulfate potassium nitrate barium chlorate potassium persulfate barium nitrate silver nitrate barium peroxide sodium carbonate peroxide calcium chlorate sodium dichloro-s-triazinetrione calcium nitrate sodium dichromate calcium peroxide sodium nitrate cupric nitrate sodium nitrite hydrogen peroxide (8-27.5%) sodium perborate lead nitrate sodium perborate tetrahydrate lithium hypochlorite sodium perchlorate monohydrate lithium peroxide sodium persulfate magnesium nitrate strontium chlorate magnesium perchlorate strontium nitrate magnesium peroxide strontium peroxide nickel nitrate zinc chlorate nitric acid (<70% conc.) zinc peroxide perchloric acid (<60% concen.) Class 2 calcium hypochlorite (<50% wgt) potassium permanganate chromium trioxide (chromic acid) sodium chlorite (<40% wgt.) halane sodium peroxide hydrogen peroxide (27.5-52% conc.) sodium permanganate nitric acid (>70% conc.) trichloro-s-triazinetrione Class 3 ammonium dichromate potassium chlorate hydrogen peroxide (52-91% conc.) potassium dichloroisocyanurate calcium hypochlorite (>50% wgt.) sodium chlorate perchloric acid (60-72.5% conc.) sodium chlorite (>40% wgt.) potassium bromate Class 4 ammonium perchlorate ammonium permanganate guanidine nitrate hydrogen peroxide (>91% conc.) perchloric acid (>72.5%) potassium superoxide

Flame Flammables Pyrophorics Self-Heating Emits Flammable Gas Self-Reactives Organic Peroxides Pyrophoric chemicals are liquids and solids that will ignite spontaneously in air at about 130 degrees F. Titanium dichloride and phosphorus are example of pyrophoric solids; tributylaluminum and related compounds are examples of pyrophoric liquids. From Wikipedia on organic peroxides: In polymer chemistry Organic peroxides find numerous applications, often involving similar chemistry. Thus, peroxides serve as accelerators, activators, cross-linking agents, curing and vulcanization agents, hardeners, polymerisation initiators, and promoters. Drying oils, as found in many paints and varnishes function via the formation of hydroperoxides. Methyl ethyl ketone peroxide, benzoyl peroxide and to a smaller degree acetone peroxide are used as initiators for radical polymerization of some resins, e.g. polyester and silicone, often encountered when making fiberglass.

Exploding Bomb Explosives Self-Reactives Organic Peroxides Self-reactive Substances What are unstable chemicals? Unstable or self-reactive substances are chemicals which have the potential to vigorously polymerize, decompose, condense, or become self-reactive under conditions of shock, pressure, temperature, light, or contact with another material. Major types of highly reactive chemicals are explosives, peroxides, water-reactives, and pyrophorics. What should I do when handling unstable chemicals? • Always wear safety goggles, closed toe shoes, and gloves • Handle under a hood if the reaction has the potential of creating gases • If there is a chance of explosion, use barriers or other forms of isolation methods • For some heat sensitive materials, temperature should be controlled. • Date all containers when received or opened

Skull and Crossbones Acute Toxicity (fatal or toxic)

Corrosion Skin Corrosion/Burns Eye Damage Corrosive to Metals Acids have better warning properties than bases. Acids will burn quickly, the victim will seek water, FAST. Caustics, poor warning properties: slippery feeling, break down proteins in the skin.

Gas Cylinder Gases Under Pressure

Health Hazard Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity

Environment Aquatic Toxicity (Non-Mandatory) Straightforward. Dead fish, dead tree.

Exclamation Mark Irritant (skin and eye) Skin Sensitizer Acute Toxicity Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (Non-Mandatory) Exclamation mark is for the weaker end. Irritant (Skin Irritation Category 2 and Eye Irritation Category 2A), Dermal Sensitizer (Category 1), Acute Toxicity (Category 4, harmful), Target Organ Toxicity/ STOT Category 3 = narcotic effects, respiratory irritation

Label Example Xyz Chemical Co. Warning First Aid Flammable Liquid and Vapor Harmful if Swallowed May Cause Damage to Organs (Liver) May Cause Damage to Organs through prolonged or repeated exposure (Heart) First Aid If swallowed If on skin

Workplace labeling Same workplace –specific labeling. Make sure the labeling system is updated to be consistent with the new classifications. NFPA/HMIS Systems - NO (rating systems v. classification) GHS and NFPA/HMIS Reversed

Secondary labeling Employers have more flexibility. The basic requirement for workplace labeling is as follows: “the final rule retains the flexibility by indicating that the employer can choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard.” The HCS 2012 specifically states for workplace container labeling that labels must contain GHS label elements (pictograms, etc.) OR “Product identifier and words, pictures, symbols, or combination thereof, which, in conjunction with the other information immediately available to the employee under the HC program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.”

g) Safety data sheets Mandates 16-section SDS headings, order of information, and what information is to be provided under the headings. Will not enforce sections 12-15 that require information outside OSHA’s jurisdiction.

16- section safety data sheet 1. Identification of the substance or mixture and of the supplier 10. Stability and reactivity 2. Hazard identification 11. Toxicological 3. Composition/information on ingredients Substance/Mixture 12. Ecological information 4. First aid measures 13. Disposal considerations 5. Firefighting measures 14. Transport information 6. Accidental release measures 15. Regulatory information 7. Handling and storage 16. Other information including information on preparation and revision of the SDS 8. Exposure controls/personal protection 9. Physical and chemical properties

h) Employee information and training Clarifies that the labels on shipped containers and workplace labels must be explained, as well as SDS format. Workers will have to be trained on the new label and SDS formats before all the provisions of the rule are effective.

Training, continued Labeling elements Train the employees on the type of information that the employee would expect to see on the new labels. How they might use that information Product identifier, Signal Word, hazard statement(s), pictogram(s), precautionary statement(s), and name, address and phone number of the responsible party. General understanding of how the elements interact For example – explain there are two signal words: Danger means a more severe hazard within a hazard class. Warning is for less severe hazard. Safety Data Sheet Train the employees on the standardization 16 section format and the type of information they would find in the various sections.

Trade secrets Allows specific chemical identity to be protected when it is a legitimate trade secret. Specifies conditions for protection or for release when there is a safety and health need for information. The percentage of a substance in a mixture is also considered to be a type of trade secret subject to the provisions in the rule.

Compliance dates Became effective May 25, 2012 Employees to be trained by December 1, 2013 Update alternative workplace labeling and hazard communication program as necessary by June 1, 2016

Personal Protection Equipment Assessment required Each task Signed by CEO

PPE Assessment Operation Hazard PPE Required Emptying Patient Trash BBP Nitrile/Latex Gloves Cleaning Patient Room