Hazard Communication and the Globally Harmonized System (GHS) Training for the workers to understand the new hazard communication rules The information contained in this presentation is sourced from the United States Department of Labor Hazard Communication Website

Hazard Communication and the Globally Harmonized System (GHS) Overview New training deadlines Why OSHA adopted the GHS Overview of the changes to the HazCom Standard Overview of Compliance Assistance Resources

Employee Information and Training H AZ C OM 1994 Requires employee information and training before a worker is exposed to the hazardous chemicals in the workplace, and whenever the hazard changes. H AZ C OM 2012 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 Employers shall train employees regarding the new label elements and safety data sheets format by December 1, 2013.

Effective Dates – HazCom 2012 Effective Completion DateRequirement(s)Who December 1, 2013Train employees on the new label elements and SDS format. Employers June 1, 2015* December 1, 2015 Comply with all modified provisions of this final rule, except: Distributors may ship products labeled by manufacturers under the old system until December 1, Chemical manufacturers, importers, distributors and employers June 1, 2016Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers Transition PeriodComply with either 29 CFR (this final standard), or the current standard, or both All chemical manufacturers, importers, distributors and employers *This date coincides with the European Union implementation date for classification of mixtures.

The Workplace For Employers »Initial employee training on the label elements »Minimal training on new SDS format »Continue to maintain the updated SDSs »Review current hazard communication program and update as necessary For Manufacturers »Initial start-up costs associated with reclassification, producing new labels, safety data sheets, training

Why did OSHA align the HCS with GHS? A common, coherent approach to classifying and communicating chemical hazards. »Harmonized definitions of hazards »Specific criteria for labels »Harmonized format for safety data sheets

Benefits of Adopting the GHS Increase the quality and consistency of information provided to the workers, employers and chemical users. »Reduce confusion/Increase comprehension of hazards. »Improve downstream risk management. »Facilitate training. »Help address literacy problems. Other benefits include facilitation of international trade in chemicals.

Notable changes “Safety Data Sheet” (Rather than a “Material Safety Data Sheet”) now uses a 16 section format Labels are more defined and will now require: »Product identifier »Pictogram »Signal word »Hazard statement(s) »Precautionary statement(s) »Name, address, and telephone number

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

HCS Pictograms and Hazards

OSHA is requiring red borders regardless of the shipment’s destination. The red borders increase comprehensibility. Blank red diamonds are not permitted on a label. Red vs. Black Borders

OSHA proposed to require labels to be updated within three months of getting new and significant information about the hazards. The final rule requires containers shipped six months after the information is available to be labeled accordingly. Updating Labels

Label Example

Workplace Labeling OSHA is maintaining the approach used in the current HCS that allows employers to use workplace-specific labeling systems as long as they provide the required information. However, such workplace label systems may need to be updated to make sure the information is consistent with the new classifications.

Safety Data Sheets H AZ C OM 1994 Specifies what information is required, but chemical manufacturer or importer can use whatever format or order of information they want. H AZ C OM 2012 Mandates 16-section SDS headings, order of information, and what information is to be provided under the headings. Will not enforce sections that require information outside OSHA’s jurisdiction.

16-Section Safety Data Sheet 1.Identification of the substance or mixture and of the supplier 2.Hazards identification 3.Composition/information on ingredients Substance/Mixture 4.First aid measures 5.Firefighting 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 12.Ecological information (non mandatory) 13.Disposal considerations (non mandatory) 14.Transport information (non mandatory) 15.Regulatory information (non mandatory) 16.Other information including information on preparation and revision of the SDS

Sections of the Safety Data Sheet 1. Identification – Include Product identifier used on label Manufacturer or distributor name Address, phone number of manufacturer or distributor Emergency phone number Recommended use Restrictions on use

Sections of the Safety Data Sheet 2. Hazard(s) Identification – Includes all Hazards regarding the chemical; required label elements a) Hazard Classification of the chemical such as skin corrosion/irritation, serious eye damage, eye irritation b) Signal Word to alert employees of a potential hazard. Two words are used: DANGER for severe hazards and WARNING for less severe hazards Hazard Statement(s) describing the nature and degree of the hazard

Sections of the Safety Data Sheet Symbol(s) which may be graphical in nature or the name of the symbol, e.g. Flame, Skull & Crossbones

Sections of the Safety Data Sheet Precautionary Statement(s) which recommends the measures taken to minimize or prevent adverse effects resulting from exposure or improper storage or handling c) Unclassified hazards e.g. combustible dust or explosion hazard; d) Where an ingredient with unknown acute toxicity is used in a mixture at a concentration greater than or equal to 1%, a statement that “x” percent of the mixture consists of ingredient(s) of unknown toxicity is required.

Sections of the Safety Data Sheet 3. Composition/Information on Ingredients – Includes information on chemical ingredients; trade secret claims For Substances - Chemical name; - Common name and Synonyms; - CAS number and other unique identifiers; - Impurities and stabilizing additives, which are themsellves classified, and which contribute to the classification of the substance.

Sections of the Safety Data Sheet 3. Composition/Information on Ingredients – (continued) For Mixtures The chemical name and concentration or concentration ranges of all ingredients. For all chemicals where trade secret is claimed Where a trade secret is claimed, a statement the specific chemical identity and/or percentage of composition has been withheld as a trade secret is required.

Sections of the Safety Data Sheet 4. First-aid Measures – Important symptoms/effects, acute, delayed; required treatment a) Description of necessary measures, subdivided according to the different routes of exposure (ie., inhalation, skin and eye contact, and ingestion) b) Most important symptoms/effects, acute delayed c) Indication of immediate medical attention/ special treatment needed.

Sections of the Safety Data Sheet 5. Fire-Fighting Measures Lists appropriate and inappropriate extinguishing techniques and equipment. Specific hazards arising from the chemical

Sections of the Safety Data Sheet 6. Accidental Release Measures Lists emergency procedures Protective equipment Proper methods of containment and cleanup

Sections of the Safety Data Sheet 7. Handling and Storage Lists precautions for safe handling and storage Includes incompatabilities

Sections of the Safety Data Sheet 8. Exposure Controls/ Personal Protection Lists OSHA’s Permissible Exposure Limits (PEL) Threshold Limit Values (TLVs) Appropriate engineering controls Individual protection measures, such as personal protective equipment

Sections of the Safety Data Sheet 9. Physical and Chemical Properties Lists the chemical’s different characteristics such as; Appearance Odor Flash Point pH level Vapor Density Evaporation rate Viscosity

Sections of the Safety Data Sheet 10. Stability and Reactivity Lists chemical stability and possibility of hazardous reactions Includes conditions to avoid and incompatible materials

Sections of the Safety Data Sheet 11. Toxicological Information Includes information on likely routes of exposure (Such as inhalation, ingestion, skin and eye contact) Related symptoms Acute and chronic effects Numerical measures of toxicity

Sections of the Safety Data Sheet 12. Ecological Information (Non-Mandatory) Includes information on the chemical effects on the ecology

Sections of the Safety Data Sheet 13. Disposal Considerations (Non-Mandatory) Description of waste residues and information on their safe handling and methods of disposal Includes the disposal of any contaminated packaging

Sections of the Safety Data Sheet 14. Transportation Information (Non-Mandatory) Transport information such as the UN number Proper shipping name Transport hazard class

Sections of the Safety Data Sheet 15. Regulatory Information (Non-Mandatory) Safety, health and environmental regulations.

Sections of the Safety Data Sheet 16. Other Information Includes Date of Preparation or Last Revision

GUIDANCE & OUTREACH

Updated HazCom Webpage

Guidance & Outreach Highlights HCS/HazCom Final Rule »Federal Register: The Final Rule was filed on March 20th at the Office of the Federal Register and available for viewing on their Public Electronic Inspection Desk. The Federal Register published the final rule on March 26, The effective date of the final rule is 60 days after the date of publication. HCS Comparison: HazCom 1994 and Hazcom 2012 »Side-by-side »Redline Strikeout of the Regulatory Text HazCom 1994

Guidance & Outreach

Press Release: US Department of Labor's OSHA publishes final rule to update the Hazard Communication Standard (HCS) Guidance »OSHA Briefs »Fact Sheet »Quick Cards

Guidance & Outreach OSHA is developing an array of guidance materials Initial Materials »Quick cards, OSHA briefs, booklets, small entity compliance guides Technical Materials »Model training materials; Safety Data Preparation guidance; Hazard Classification Guidance Web Applications »SDS Electronic Form; Label Elements Application; Acute Toxicity Calculator

Updated Webpages HazCom 2012 Webpage » Safety & Health Topics Webpage »

UN GHS Links & Information United Nations Economic Commission for Europe GHS Sub- committee s/danger/publi/ghs/ghs_w elcome_e.html