1. Hazard Communication

2. Standard Sections Purpose Employee Information and Training
Scope and Application
Trade Secrets
Definitions
Effective Dates
Hazard Classification
Appendices A–F
Written Hazard Communication Program
Labels and Other Forms of Warning
Safety Data Sheets

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

4. Downstream employer requirements
Hazard Communication Program
Secondary (workplace) labeling
SDS maintenance
Training

5. Hazard Classification
Manufacturers are responsible for determining the hazards of the chemicals they produce or import.
Classifications are based on the full range of available information.
Appendix A (health)
Appendix B (physical).

6. Hazard Classification
Each physical or health hazard is a “hazard class” (e.g., Carcinogenicity is a hazard class).
A “hazard class” may be sub-divided in the criteria into several “hazard categories” based on the degree of severity of the hazard.

7. Appendix A: Health Hazards
Hazard Class
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 – Single Exposure
STOT – Repeated Exposure
Aspiration
Simple Asphyxiants
Single Category

8. Example of a Hazard Class w/Categories (Appendix A: A
Example of a Hazard Class w/Categories (Appendix A: A.1): Acute Toxicity
Exposure route
Category 1
Category 2
Category 3
Category 4
Oral (mg/kg bodyweight)
see: Note (a)
Note (b)
≤ 5
>5 and ≤ 50
>50 and ≤ 300
>300 and ≤ 2000
Dermal (mg/kg bodyweight)
≤ 50
>50 and ≤ 200
>200 and ≤ 1000
>1000 and ≤ 2000
Inhalation - Gases (ppmV)
see: Note (a)
Note (c)
≤ 100
>100 and ≤ 500
>500 and ≤ 2500
>2500 and ≤ 20000
Inhalation - Vapors (mg/l)
Note (d)
≤ 0.5
>0.5 and ≤ 2.0
>2.0 and ≤ 10.0
>10.0 and ≤ 20.0
Inhalation –
Dusts and Mists (mg/l)
≤ 0.05
>0.05 and ≤ 0.5
>0.5 and ≤ 1.0
>1.0 and ≤ 5.0

9. Appendix B: Physical Hazards
Hazard Class
Hazard Category
Explosives
Unstable Explosives
Div 1.1
Div 1.2
Div 1.3
Div 1.4
Div 1.5
Div 1.6
Flammable Gases 1 2
Flammable Aerosols
Oxidizing Gases
Gases under Pressure
Compressed Gases
Liquefied Gases
Refrigerated Liquefied Gases
Dissolved Gases
Flammable Liquids 3 4
Flammable Solids
Self-Reactive Chemicals
Type A
Type B
Type C
Type D
Type E
Type F
Type G
Pyrophoric Liquids
Pyrophoric Solid
Pyrophoric Gases
Single category
Self-heating Chemicals
Chemicals, which in contact with water, emit flammable gases
Oxidizing Liquids
Oxidizing Solids
Organic Peroxides
Corrosive to Metals
Combustible Dusts

10. Other Categories Simple Asphyxiant Pyrophoric Gas Combustible Dust
Hazards Not Otherwise Classified

11. Label Requirements Labels on shipped containers must include:
Product Identifier
Signal Word
Pictogram
Hazard Statement(s)
Precautionary Statement(s)
Supplier Identification (Name, Address, Phone Number)

12. Signal Word
“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

13. Hazard Statement
“Hazard statement” means a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard
Example: Fatal if swallowed (Acute Oral Toxicity)

14. Precautionary Statement
“Precautionary statement” means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling
Example: Do not eat, drink, or smoke when using this product
Example: Keep container tightly closed

15. Precautionary Statements, cont.
The statements assigned to a chemical address the following four areas
Prevention
Response
Storage
Disposal

16. Labels
Precautionary statements and hazard statements may be combined or consolidated to save label space and improve readability

17. Pictograms OSHA is requiring red borders on shipped containers
Blank red diamonds are not permitted on a label.

18. Pictogram
“Pictogram” means a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical
Eight pictograms are designated under this standard for application to a hazard category

19. HCS Pictograms and Hazards

20. Labels, cont.
A DOT label (placard) is required for transport. An OSHA/HCS label is required for the workplace
The DOT and HCS labels may appear for the same hazard, depending upon the container’s use
Consumer products subject to CPSC labeling requirements are exempted from the labeling requirements of the HCS

21. Examples of Transport “Labels”

22. Label Example

23. Labels Small Packages Pictograms No size requirements for labels
No exemptions for small packages – NIST letter
OSHA provides practical accommodations on a case-by-case basis
Pictograms
Blank pictograms are not permitted on a label
No size requirements for labels

24. Workplace Labeling
No change to general workplace labeling requirements
HMIS labels and NFPA ratings

25. Safety Data Sheets (SDS) Appendix D
Specific format (16 section)
Specific information in each section
ACGIH TLVs continue to be required on the SDS.
Information regarding carcinogenicity classifications by IARC and NTP also continue to be required.

26. 16-Section Safety Data Sheet
Identification of the substance or mixture and of the supplier
Ecological information (non mandatory)
Hazards identification
Disposal considerations (non mandatory)
Composition/information on ingredients Substance/Mixture
Transport information (non mandatory)
First aid measures
Firefighting measures
Regulatory information (non mandatory)
Accidental release measures
Other information including information on preparation and revision of the SDS
Handling and storage
Exposure controls/personal protection
Physical and chemical properties
Stability and reactivity
Toxicological

27. Safety Data Sheets, cont.
Component disclosure on SDSs
Options for using ranges instead of exact percentages include trade secret, batch-to-batch variation, similar mixtures
With very small variances or tolerances during production, the anticipated percentage in the formula may be used
In all cases the concentration ranges must have no effect on the hazard of the mixture

28. SDS, cont.
Section headings for SDS sections must still be listed on the SDS; OSHA will not be enforcing the content of these sections
The requirements to maintain MSDSs or SDSs under 29 CFR have not changed
The conditions under which employers may maintain SDSs electronically in the workplace have not changed
SDSs must be in English; they may also be kept in other languages
A red border is not required for pictograms on SDSs
Hazards Not Otherwise Classified should be described in Section 2 of the SDS

29. Safety Data Sheets Distribution
An updated SDS must be provided with products shipped by June 1, 2015
Companies are not required to send new SDSs to previous customers who may still have the product in inventory
New SDSs do not have to be provided for chemicals no longer produced

30. SDS Requirements
SDSs must be readily accessible to workers when they are in their work areas, during each work shift
Most current version received must be maintained

31. Hazard Communication Program
Labels
SDSs
Training
Inventory
Non-routine tasks
Multi-employer workplace
Must make available
May be kept at main site

32. Available documents Quick cards OSHA briefs Booklets
Small entity compliance guides
Hazard Communication Directive
Letters of Interpretation

33. Questions?