1. GHS Hazard Communication
June 17, 2013

2. Yes No Don’t know what GHS is A B C
Have you started using any GHS elements in your Hazard Communication training? A
Yes B No C
Don’t know what GHS is

3. Overview
Purpose
Definitions
GHS Changes
Pictograms

4. OSHA Standard
Several states enacted their own “Right to Know” law
Chemical manufacturers wanted one uniform law vs. various state laws
Ordered by Congress -1985
Global Harmonization Standard (GHS) added in 2012
Major Changes in the Hazard Communication Standard include:
Hazard classification: The revised standard provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
Labeling: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
Safety Data Sheets: Will now have a specified 16-section format and the name changes from Material Safety Data Sheet (MSDS) to Safety Data Sheet (SDS).
Information and training: Employers are required to train workers by December 1, 2013 on the new labels elements and safety data sheets format to facilitate recognition and understanding

5. The Problem
4,609 fatal work injuries were recorded in the United States in 2011,
4,690 fatal work injuries in 2010
And work-related illnesses cause about 49,000 deaths each year, according to the CDC.
You have a right to know the hazards of chemicals in the workplace.

6. Purpose
To ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards are transmitted to employers and employees.
Accomplished with:
container labeling
material safety data sheets
employee training
GHS is about a globally harmonized system for hazard communication and labeling, what we call hazard communication.
It is important to remember what the hazard communication standard is intended to accomplish.
The goal is good, to inform people about the hazards of the chemicals they are working with. If employers and employees don’t understand the hazards they are working with, they are not going to successfully protect themselves and more injury and illness will occur.
At least four things can interfere with the ability of the HCS to accomplish its goals
Quality of the hazard evaluation
Quality of the information applied to labels and MSDSs
Ability of users to understand the information
Lack of consistency 6

7. Outline of Standard
(a) Purpose (b) Scope (c) Definitions (d) Hazard Classification (e) Written Hazard Communication Program (f) Labels and Other Forms of Warning (g) Safety Data Sheets (h) Employee Information and Training (i) Trade Secrets (j) Effective Dates (k) Other Standards Affected (l) Appendices

8. Definitions
Terms no longer being defined due to changes in terminology:
Hazard warning; identity; and material safety data sheet (MSDS)
Terms revised to be consistent with the GHS:
Chemical; chemical name; hazardous chemical; health hazard; label; mixture; physical hazard; and trade secret
In addition, the following terms are not being defined in because they are no longer needed due to changes in terminology: Hazard warning; identity; and material safety data sheet (MSDS). Regarding material safety data sheet, this term was removed, but is replaced by the new term safety data sheet.
The definitions for the following terms are being revised to be consistent with the GHS and, ultimately, Haz Com 2012: Chemical; chemical name; hazardous chemical; health hazard; label; mixture; physical hazard; and trade secret 8 8 8 8

9. Definitions
The following terms are being added to the definitions section:
Classification; hazard category; hazard class; hazard not otherwise classified; hazard statement; label elements; pictogram; precautionary statement; product identifier; pyrophoric gas; safety data sheet (SDS); signal word; simple asphyxiant; and substance
Most of the terms added to the definitions paragraph of Haz Com 2012 are related to evaluating hazards and proper label information.
For example – classification requires manufacturers, importers, and distributors to evaluate the hazards of the chemicals they produce, and select the appropriate hazard class and hazard category, using the criteria provided in Appendices A and B. As I will discuss in a little bit, the classification approach is different than the determination approach used in Haz Com 1994.
You’ll notice that pyrophoric gas and simple asphyxiant are listed as definitions added to this paragraph of the rule. These hazards were included in Haz Com 1994, but are not included in the GHS. OSHA added these hazard definitions to Haz Com 2012 so that the rule would maintain its existing hazard coverage. 9 9 9 9

10. Definitions “Chemical”
OSHA previously used “chemical” to indicate both substances and mixtures
OSHA has decided to continue using “chemical” in the final rule as meaning those situations where both substances and mixtures are being addressed
“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
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. 10 10 10 10

11. Definitions “Hazards Not Otherwise Classified”
Classified identifies a hazard, but the evidence does not meet the currently specified criteria covered by Haz Com 2012
Example: Static Accumulator, Magnetic, etc.
Information will be required on the safety data sheets in Section 2
Hazard information on the label, is not mandatory, but can be provided under supplementary information
Such hazards must also be addressed in worker training
Information on hazards not otherwise classified is required to be provided in Section 2 of the safety data sheet. That’s the Hazard Identification section of the safety data sheet.
However, information for hazards not otherwise classified is not required on the label, but it can be provided as supplemental information.
Of course, if such a hazard is identified, it must be included in worker training.
What's an example of a hazards not otherwise classified?? Static accumulator
The definition for hazards not otherwise classified is intended to address situations where a classifier has identified evidence of a hazard during the normal classification process, but the evidence does not meet the currently specified criteria for hazards covered by Haz Com 2012.
The definition for hazards not otherwise classified captures those effects to ensure that Haz Com 2012 is appropriately protective, and covers all of the hazards covered by Haz Com 1994.
You see, Haz Com 1994 was an umbrella standard, designed to capture chemical hazards in the workplace, even those that had not been identified at the time the rule was promulgated. By including a definition for hazards not otherwise classified, we are maintaining this coverage. 11 11 11 11

12. Definitions
“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.
For example: Wear face protection [for Explosives, Division 1.1]
Precautionary statements describe recommended measures that should be taken to protect against hazardous exposures, or improper storage or handling of a chemical. 12 12 12 12

13. (d) Hazard Classification
Each type of hazard covered is considered a “hazard class”—such as acute toxicity, carcinogenicity
However, most of these hazard classes are also sub-divided into “hazard categories” to reflect the degree of severity of the effect
This is the concept of “classification”—rather than just determining that there is a hazardous effect (carcinogenicity), there is also a finding of how severe that effect might be (Category 1 or 2)
This paragraph requires that chemical manufacturers and importers identify and evaluate the available scientific evidence on a chemical to determine if it is hazardous, as well as determine the degree of hazard using the criteria for health and physical hazards located in Appendices A and B.
Hazard classification provides the basis for the hazard information that is provided on labels, SDSs, and in employee training. Therefore, it is important that classification be performed accurately and consistently.
Each type of hazard covered is considered a “hazard class”—such as acute toxicity or carcinogenicity
And most of these hazard classes are also sub-divided into “hazard categories” to reflect the degree of severity of the effect (for instance- category 1, or category 3)
The general concept of classification is to determine the hazardous effect (such as carcinogenicity) and the severity of the effect (such as category 1 or category 2) 13 13 13 13

14. (d) Hazard Classification
Classification Provisions
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
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) 14 14 14 14

15. Health Hazards Classifications
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
Repeated Exposure
Aspiration
Simple Asphyxiants
Single Category
This slide contains all of the health hazard classes covered under Hazcom 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.

16. Physical Hazards
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 HazCom 1994 for physical hazards in HazCom 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 ). 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. 16 16 16 16

17. (e) Program Requirements
Written program
List of all hazardous chemicals
Must Address all non-routine tasks
Discuss and update contractor responsibilities
SDS (Safety Data Sheets) must be available upon request to any employee or contractor
Some people, especially in small to midsize companies, are intimidated by the task of developing a written program, but there are many resources at and other Websites that simplify the work by providing a basic template to follow.

18. (e) Written Program
Must describes how the standard will be implemented in your facility  
Must contains a list of all chemicals within facility
Your written program must be revised to comply with the new standard including training, labeling, SDS management, and hazard classification. Other updates may also be necessary if some of these required changed also change how you manage your Hazcom program. Written programs must be updated by June 1, 2016.

19. (f) Labels Required Elements
Product identifier
Signal words
Hazard statements
Pictograms
Precautionary statements
Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party
A new Appendix C, Allocation of Label Elements, has been provided to indicate the label requirements by hazard class and category
Labels are to be updated within 6 months of getting new and significant information about the hazards, or ways to protect those exposed
Hazcom 2012 requires that labels on shipped containers contain much more information than required by Hazcom 1994, such as:
the product identifier,
signal word,
hazard statement(s),
pictogram(s),
precautionary statement(s),
and the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.
However, much of this additional information is already included on labels by manufacturers, particularly for those following the ANSI standard Z129 for precautionary labeling.
These elements are intended to be the minimum information to be provided on labels by manufacturers and importers.
So, if chemical manufacturers and importers want to provide additional information regarding the hazards of a chemical as well as precautions for safe handling and use, they are free to do so
as long as the information is accurate, and
does not conflict with the required label elements
All of the label requirements by hazard class and category can be found in Appendix C 19 19 19 19

20. (f) Labels
OSHA is maintaining the current approach to allowing alternatives to labels on each stationary process container
The exception for portable containers under the control of the person who filled them with the chemical remains the same.
Labels on incoming containers are not to be removed or defaced unless immediately replaced by another label
Workplace labels are to be prominently displayed and in English, although other languages are permitted as well
As of Dec. 1, 2015*, all labels will be required to have:
1. Pictograms
2. A signal word
3. Hazard and precautionary statements
4. The product identifier and supplier identification
*Employers have until June 1, 2016 to ensure that in-house labels have been updated. All employees must be trained on new labeling requirements and pictograms by Dec. 1, As of Dec. 1, 2015, manufacturers and importers may not ship products without the new labels 20 20 20 20

21. Pictograms
This slide displays all 9 GHS pictograms. But as previously stated, OSHA is only requiring 8 of them

22. (f) Labels Example
Use the Pointer to show the label elements. 22

23. (f) Labels Sample HS85 Label
Warning
Batch number: 85L6543
Harmful if swallowed. Wash hands and face thoroughly after handling. Do not eat, drink or smoke when using this product. Dispose of contents/container in accordance with local, state and federal regulations.
First aid: If swallowed: Call a doctor, Rinse mouth.
GHS Example Company, 123 Global Circle, Anyville, NY 130XX
Emergency Telephone (888)
Use the Pointer to show the label elements.
A word about emergency telephone numbers. If a company has an emergency telephone number it must be displayed…… 23 23 23

25. (f) Labels
Employers are responsible for maintaining the labels on the containers, including, but not limited to, tanks, totes, drums, and for training their employees on the hazards listed on the labels in the workplace.
Labels must continue to be:
legible
contain the pertinent information (such as the hazards and directions for use)
not able to be defaced, (i.e., fade, get washed off,) or removed in any way as stated in revised Hazard Communication Standard, 29 CFR  (f)(9)
Employers are still responsible for the same hazard communication on labels as before. 25

26. (g) Safety Data Sheets (SDS)
The GHS uses a specified order of information, as well as title descriptions, on the 16-section safety data sheet.
Health, physical and environmental hazard criteria for substances and for classification of mixtures.
Consistent with voluntary industry consensus standards, such as ANSI.
Should improve comprehensibility and issues regarding accuracy of information.
Under the HCS, the safety data sheet (SDS) is the detailed reference source on the chemical, addressing all aspects of hazard information as well as methods for safe handing and use. The HCS specifies what information must be included on the data sheet, but does not specify a format or order of information. Having a standardized order of information should improve comprehensibility and should make it easier for chemical manufacturers to comply by providing them with a template to follow.
The GHS safety data sheet (SDS) is to include the following in this order:
Chemical Identification
Hazard Identification
Composition/information on ingredients
First aid measures
Firefighting measures
Accidental release measures
Handling and storage
Exposure controls/personal protection
Physical and chemical properties
Stability and reactivity
Toxicological information
Ecological information
Disposal considerations
Transport Information
Regulatory Information
Other Information 26

27. (g) Safety Data Sheet (SDS) Format
Identification of the substance or mixture and of the supplier
2. Hazards identification
Composition/information on ingredients
4. First-aid measures
5. Fire-fighting measures
Accidental release measures
7. Handling and storage
Exposure controls/personal protection
Physical and chemical
properties
10. Stability and reactivity
11. Toxicological information
Ecological information
(non-mandatory)
Disposal considerations
Transport information
Regulatory information
Other information, including
date of preparation or last
revision  
This slide lists the section headings of the SDS. To be consistent with the GHS, the revised standard requires that Sections 12 through 15 be listed on the SDS. 27 27 27 27

28. (g) Safety Data Sheets (SDS)
SDS in the workplace for each hazardous chemical which is used
OSHA requires these forms for each hazardous chemicals
Readily accessible during each work shift to employees when they are in their work area(s)

29. (g) Safety Data Sheets (SDS)
Identifies chemicals by name
Tells potential harm and how chemicals will enter the body (Inhalation, ingestion, and/or skin absorption)
Explains signs and symptoms of exposures
Explains emergency procedures

30. (h) Employee Training
Although this paragraph remains essentially the same, updates include
Training to include label elements and new safety data sheet format - by December 1, 2013
Training to reflect any new hazards identified in the workplace - by June 1, 2016
Training – prescribed label elements and order of information on data sheets facilitate training/comprehensibility.
Training will be necessary to ensure that employees understand the new elements, particularly on the new pictograms. Therefore, modified training requirements have been included in the final rule in order to address the new label elements and SDS format required under this revised standard.
Remember: we are not changing what goes on the SDS just how it goes on the SDS
All employers shall update the hazard communication program required by paragraph (h)(1), and provide any additional employee training in accordance with paragraph (h)(3) for newly identified physical or health hazards no later than June 1, 2016.
Training shall include: What are pictograms; what are the signal words; what are Hazard Statements; and what are precautionary statements. 30 30 30

31. (h) Employee Training
Trained initially and when new chemical introduced
OSHA standard covered
Operations in their work area where chemical is used
Pictograms
Location of program, list of chemical, and SDS
Detection of chemical
Hazards of chemical
Protection measures
Emergency procedures
Labeling system used

32. Temporary Employees
The temporary agency employer would provide generic hazard training and information concerning categories of chemicals employees may potentially encounter
Host employers would then be responsible for providing site-specific hazard training pursuant to sections (h)(1)
It is the responsibity of host corporation to verify that all contractors have received HazCom Training.

33. Compliance Issues
Can your employees retrieve information stored on a computer?
If you have employees who speak a language other than English how do you ensure that these employees understand your labels, what about your foreign customers i.e. non EU.
Who puts labels on portable containers?

34. More Issues
How is the outside contractor informed of chemicals in the area?
What do you do if the label falls off an old container?
How is chemical piping labeled?
What chemicals do I have that may contain cancer causing chemicals?

35. FLAMMABLE LIQUIDS (Classified in Accordance with Appendix B.6)
Pictogram Flame
Hazard category
Signal
word
Hazard statement 1
Danger
Extremely flammable liquid and vapor (old 1A) 2
Highly flammable liquid and vapor (old 1B) 3
Warning
Flammable liquid and vapor
This is prior to the new GHS Protocol.
Pictogram No Pictogram
Hazard
category
Signal word
Hazard statement 4
Warning
Combustible liquid

36. Revision of 29 CFR 1910.106 Flammable Liquids
Flammable liquids are divided into four categories as follows: (i) Category FPs below 73.4 o F (23 o C) and having a BP at or below 95 o F (35 o C). (ii) Category FPs below 73.4 o F (23 o C) and BP above 95 o F (35 o C). This was the old IB (iii) Category FPs at or above 73.4 o F (23 o C) and at or below 140 o F (60 o C). (iv) Category FPs above 140 o F (60 o C) and at or below o F (93 o C).
This is the revision

37. Revision of 29 CFR 1910.106 Flammable Liquids
GHS
Flammable and Combustible Liquids Standard
(29 CFR )
Category
Flashpoint ºC (°F)
Boiling
Point
ºC (°F)
Class
Boiling Point
Flammable 1
< 23 (73.4)
≤ 35 (95)
Flammable Class IA
< 22.8 (73)
< 37.8 (100)
Flammable 2
> 35 (95)
Flammable Class IB
≥ 37.8 (100)
Flammable 3
≥ 23 (73.4) and ≤ 60 (140)
Flammable Class IC Combustible Class II
≥ 22.8 (73) and < 37.8 (100)
≥ 37.8 (100) and < 60 (140)
Flammable 4
> 60 (140) and ≤93 (199.4)
Combustible Class IIIA
≥ 60 (140) and <93.3 (200)
None
Combustible Class IIIB
≥ 93.3 (200)
** Not covered by § or § however interpretation letter indicates these are covered by §

38. Safety Standards Flammable Liquids 1910.106
HCS 1994
Flame arresters or venting devices required in subdivision (f) of this subdivision may be omitted for Class IB and IC liquids where conditions are such that their use may, in case of obstruction, result in tank damage.
HCS 2012
(g) Flame arresters or venting devices required in paragraph (B)(2)(iv)(f) of this section may be omitted for Category 2 flammable liquids and Category 3 flammable liquids with a flashpoint below 100 °F (37.8 °C) where conditions are such that their use may, in case of obstruction, result in tank damage.
A good reference
NOTE: Read the HCS 1994 standard and explain how the terminology was revised in the HCS The terminology was revised to make it consistent with the how the HCS was revised to align with the GHS. A good reference 38

39. Safety Standards PSM 1910.119(a)(1)(ii)
HCS 1994
A process which involves a flammable liquid or gas (as defined in (c) of this part) on site in one location, in a quantity of 10,000 pounds ( kg).
HCS 2012
A process which involves a Category 1 flammable gas (as defined in (c)) or a flammable liquid with a flashpoint below 100 °F (37.8 °C) on site in one location, in a quantity of 10,000 pounds ( kg)
OSHA took a similar approach to the PSM standard. If they had not made these changes in terminology, then the scope of the standard would have changed.
The terminology was revised to make it consistent with the how the HCS was revised to align with the GHS. 39

40. (j) Effective Dates Effective Completion Date Requirement's) Who
December 1, 2013
Train employees on the new label elements and safety data sheet (SDS) format.
Employers
June 1, 2015*
December 1, 2015
Compliance with all modified provisions of this final rule, except:
The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label
Chemical manufacturers, importers, distributors and employers
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 to the effective completion dates noted above
May comply with either 29 CFR (the final standard), or the current standard, or both
Chemical manufacturers, importers, distributors, and employers
In the final rule OSHA decided not to phase in compliance based on whether a product is a substance or a mixture. OSHA concluded that adequate information is available for classifiers to use to classify substances and mixtures.
Therefore, under the revised standard, covered employers must complete all training regarding the new label elements and SDS format by December 1, 2013 since, employees will begin seeing the new style labels considerably earlier than the compliance date for labeling.
Talk about REACH, EPA and ECHA Statement of Intent, ASEAN’s passing of REACH like legislation.
All other provisions to be in effect by June 1, 2015, except:
Distributors who are passing on manufacturer labels to customers shall ensure all labels are updated by December 1, 2015 ( these distributors have an extra six months) IF distributors are not passing along manufacturer labels they MUST comply with the June 1, 2015 date for labels.
Employers will also be given an additional year (by June 1, 2016) to update their hazard communication programs or any other workplace signs, if applicable.
You may be curious about, or get asked “Why did OSHA pick June 1, 2015 for an effective date for labels?” This is because it coincides with the EU date for classifying mixtures. 40 40 40 40