Chemical manufacturers & importers must classify each chemical produced or imported. They must: Determine the appropriate hazard classes & associated hazard categories. Base determination on evaluation of full range of available data/evidence on the chemical (no testing required). Utilize Appendix A for health hazard criteria & Appendix B for physical hazard criteria. Employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer or importer. Must then have additional data/evidence on chemical to substantiate different classification, especially lower classification. Roles
Term used to indicate the intrinsically hazardous properties of chemicals. Classification comprised of 3 steps: 1.Identification of relevant data regarding the hazards of a chemical; 2.Review of the data to ascertain the hazards associated with the chemical; 3.Determination of whether the chemical will be classified as hazardous and the degree of hazard. “Hazard Classification”
Hazards divided first into one of three “hazard groups: 1.Physical 2.Health 3.Environmental (Not regulated under OSHA, but by EPA) Each hazard group is comprised of a “hazard class,” such as acute toxicity or carcinogenicity. Most hazard classes also sub-divided into “hazard categories” to reflect degree of severity of effect. This concept of “classification” is not only determining if there is a hazardous effect (carcinogenicity), but is also evaluating and ranking the severity of the effect (Category 1 or 2). Process
Classification of mixtures is performed on a tiered approach. 1 st Choice Classify mixture based on test data available for the complete mixture. 2 nd Choice Use “bridging” principle, which is taking test data for individual substances &/or ingredients comprising the mixture & use it to classify mixture. 3 rd Choice If no test data exist, & bridging principles won’t work, then the method(s) described in each chapter of Appendix A of the HazCom 2012 standard for estimating hazards based on known information will be applied to classify the mixture (e.g., application of cut-off values/concentration limits). Mixtures
Acute Toxicity Skin Corrosion/Irritation Serious Eye Damage/Eye Irritation Respiratory or Skin Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Specific Target Organ Toxicity – Single Exposure Specific Target Organ Toxicity – Repeated Exposure Aspiration Simple Asphyxiant Simple Asphyxiants is not one of 10 health hazards addressed in Appendix A, because not one of harmonized hazard classes in GHS. Since simple asphyxiants already covered under HazCom 1994, and OSHA didn’t want to diminish protections, simple asphyxiants have been addressed separately in final rule, with definition provided in paragraph (c) & required label elements provided in Appendix C. Health Hazard Classes
Health Hazards Criteria Appendix A of HazCom 2012
Explosives Flammable Gases Flammable Aerosols Oxidizing Gases Gases under Pressure Compressed Gas Liquefied Gas Refrigerated Liquefied Gas Dissolved Gas Flammable Liquids Self-Reactive Chemicals Pyrophoric Liquids Pyrophoric Solids Self-Heating Chemicals Chemicals which, in Contact with Water, Emit Flammable Gases Oxidizing Liquids Oxidizing Solids Organic Peroxides Corrosive to Metals Pyrophoric Gas Combustible Dusts Physical Hazard Classes OSHA tried to maintain scope of HazCom 1994 for Physical Hazards in GHS HazCom. Therefore, will notice list also includes pyrophoric gases & combustible dusts. Definition for pyrophoric gas contained in paragraph (c) & label elements presented in Appendix C. Combustible dust definition provided in Combustible Dust NEP (Directive CPL ). Guidance on hazard provided using existing documents, including those on OSHA’s webpage. In addition there are number of voluntary consensus standards (NFPA) that address combustible dust.
Physical Hazards Criteria Appendix B of HazCom 2012
Example of Criteria Information - Simple
Example of Criteria Information - Complex
Appendix C – Allocation of Label Elements
As a result of HazCom 2012 other OSHA Standards required revision to bring them into alignment with content of HazCom – Flammable & Combustible Liquids – Spray Finishing Using Flammable & Combustible Materials – Process Safety Management of Highly Hazardous Chemicals – Hazardous Waste Operations & Emergency Response to – Dipping & Coating Operations Revisions to Other Standards
Revisions
Groups Physical Health Classes Acute Toxicity Skin Corrosion/Irritation Serious Eye Damage/Eye Irritation Respiratory or Skin Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Specific Target Organ Toxicity – Single Exposure Specific Target Organ Toxicity – Repeated Exposure Aspiration Explosives Flammable Gases Flammable Aerosols Oxidizing Gases Gases under Pressure Compressed Gas Liquefied Gas Refrigerated Liquefied Gas Dissolved Gas Flammable Liquids Self-Reactive Chemicals Pyrophoric Liquids Pyrophoric Solids Self-Heating Chemicals Chemicals which, in Contact with Water, Emit Flammable Gases Oxidizing Liquids Oxidizing Solids Organic Peroxides Corrosive to Metals Pyrophoric Gas Combustible Dusts Signal Words Hazard Statement Pictogram Changes to Other Standards Summary
Flammable liquid – Category Appendix B – Physical Criteria, section B.6.2 Criteria: Flash pt 35°C Appendix C – Allocation of Label Elements, section C.4.19 Signal Word: Danger Hazard Statement: Highly flammable liquid & vapor Pictogram: Precautionary Statements: Keep away from heat/sparks/open flames/hot surfaces.– No smoking. Others as needed Exercise
Specific Target Organ Toxicity, Single Exposure – Category Appendix A – Health Hazard Criteria, section A.8 Criteria: Transient target organ effects… Appendix C – Allocation of Label Elements, section C.4.11 Signal Word: Warning Hazard Statement: May cause respiratory irritation; or May cause drowsiness or dizziness Pictogram: Precautionary Statements: Avoid breathing dust/fume/gas/mist/ vapors/spray. Others as needed Exercise