TDI Brooks HAZCOM Program (includes GHS & Final Rule 2012 updates)

1. TDI BrooksHAZCOM Program(includes GHS & Final Rule 2012 updates) SOP-GEN-013B Prepared by Shannon Smith Last Revision October 2013

2. OSHA’s HAZCOM Regulation • The OSHA Hazard Communication Regulation was passed in 1983 to protect workers from hazardous chemicals in the workplace. It established the worker’s “Right to Know” what he or she was exposed to at work.

3. OSHA’s HAZCOM Regulation • In 2012, the regulation was updated to include the United Nations’ GHS system. This revision emphasized the worker’s “Right to Understand” the hazards of the chemicals and how to protect themselves.

4. HAZCOM final rule and GHS • The Globally Harmonized System of Classification and Labeling of Chemicals, also know as GHS, is a document created by the United Nations to standardize how to classify and label hazardous chemicals among participating countries.

5. What is GHS? • The goal of the GHS was for workers of any nationality to easily recognize and understand the hazards of the chemicals they handle- regardless of language or literacy.

6. Why HazCom? • The HAZCOM Regulation, “ requires … all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets, and information and training.” • OSHA 29 CFR 1910.1200(b)(1) is the regulation number of this standard.

7. TDI’s HAZCOM Program • TDI’s HAZCOM program is contained in the Safety Management Manual as SOP-GEN-013B

8. When is HAZCOM training required? • 1910.1200(h)(1) • Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area.

9. Safety Data Sheets (formerly MSDS) • A Safety Data Sheet (SDS) is prepared by the manufacturer or importer to give information about a chemical or substance. • After Dec 2015, all Safety Data Sheets must present this information in a standard format. • Until then, SDSs may be in multiple formats.

10. SDS Binder • An SDS binder containing SDSs for all chemicals in the area should be in a centrally located, easily accessible area at all TDI Brooks facilities and on all vessels. • It should contain: • TDI Hazcom Program • A list of chemicals in at the site and • An SDS sheet for each chemical on the list.

11. ?????????????????? • Where is the nearest SDS binder? • Does it contain the policy and chemical list?

12. SDS Page on TDI Ship Web Pages • TDI Brooks has a ship based set of web pages that includes an SDS page. • The SDS page contains: • The TDI HazCom Program • A blank chemicals list form in Excel • SDSs for commonly used chemicals • Links to search engines to finds SDSs • SDSs can be downloaded and printed as needed

13. The SDS page is organized by types and departments.

14. SDS- New 16 Section Format • Section 1- Identifies product and manufacturer • Section 2- Identifies Hazards • Section 3- Composition Information • Section 4- First Aid Measures • Section 5- Fire Fighting measures • Section 6- Accidental Release/ Containment • Section 7- Handling and Storage • Section 8- Exposure Control/ PPE

15. SDS- New 16 Section Format • Section 9- Physical and Chemical Properties • Section 10- Stability and Reactivity • Section 11- Toxicology • Sections 12 through16- Ecology, disposal, transport, etc. Not regulated by OSHA

16. Identification, Manufacturer • Section 1 identifies the chemical and gives contact information- including emergency phone number- for the manufacturer.

17. Hazards • Section 2 lists all hazards and required label elements.

18. First Aid • Section 4 of the new SDS format contains first aid measures.

19. Handling and Storage • Section 7- Pay attention to this- it will tell you recommended temperature, ventilation and what NOT to store it with. (This one is for household bleach)

20. Exposure Control/ PPE • Section 8- will state recommended PPE.

21. Stability and Reactivity • Section 10- warns of any strong reactions with incompatible substances.

22. ?????????????????? • This SDS section is for acetone. Should it be stored with bleach? Why?

23. ?????????????????? No. But why?

24. ?????????????????? No. But why?

25. Labels • Manufacturer labels will be required to include four elements: • Pictogram representing the hazard • Signal Word indicating hazard level • “Warning” – less severe • “Danger” – more severe • Hazard Statement describing type and degree of hazard • Precautionary Statement of recommended measures to protect the worker

26. Sample of new label elements from SDS

27. Labeling Secondary Containers • You may transfer a product into a smaller container or spray/ squirt bottle for easier use. • But- you must label it with at least: • Product name • Words or pictograms to convey the general physical or chemical hazards

28. ?????????????????? • Is this secondary container labeled correctly?

29. ?????????????????? Is this secondary container labeled correctly? No. The product is identified, but there is no indication of the hazards.

30. ?????????????????? This secondary container lists a description of how the worker should protect him or herself. Is it labeled correctly?

31. ?????????????????? This secondary container lists a description of how the worker should protect him or herself. Yes. It indicates the hazards by telling the worker what personal protective equipment is needed

32. ?????????????????? What about this one?

33. ?????????????????? What about this one? Yes. The pictures indicate there are hazards to the skin and eyes and recommend protective equipment.

34. Some Exceptions for Labeling GHS Labeling of secondary containers according to OSHA regulations does not apply to the following (1910.1200(b)(5-6)): • Chemicals that are specifically regulated by other agencies (medical, biological, radioactive, agricultural, cosmetic) • Tobacco or tobacco products • Food or alcohol intended for consumer use

35. Other exceptions • Wood or wood products that only present flammability hazards. (not chemically treated) • Over the counter drugs, first aid supplies • Cosmetics • Any consumer product used for its intended purpose that does not present exposure greater than reasonably expected for its intended use (hand soap)

36. Memory is the first thing to go… • If this looks familiar, you need some practice making labels….

37. GHS Pictograms- why we need them

38. The real reason we need pictograms is that hazardous materials are shipped around the world and are handled daily by people from many countries and levels of education. An SDS may give all the important information about the hazards of a substance, but that is useless if the worker handling it cannot read or understand it. GHS Pictograms

39. What do these signs mean to you?

40. A warning you can’t understand is no warning at all. What you don’t know really can hurt you…

41. A picture is more effective and communicates across language and literacy barriers.

42. GHS Pictograms • There are nine pictograms adopted by the GHS to identify chemical hazards. Irritant Acutely toxic Skin sensitizer Explosives Self-Reactives Organic Peroxides Skin corrosion, burns Eye damage Corrosive to metals Aquatic Toxicity

43. GHS Pictograms Gas under pressure Acute Toxicity (fatal or toxic) • Flammable • Pyrophoric - ignites when exposed to air • Self Reactive – produces heat by itself • Respiratory Sensitizer – causes nose and throat to become hypersensitive • Target Organ Toxicity – harmful to organs • Aspiration Toxicity – harmful when inhaled

44. Health Hazard TechnicalTerms Mean the substance causes the following problems: • Cancer • Carcinogen • Mutagenicity • Reproductive Toxicity • Respiratory Sensitizer • Target Organ Toxicity • Aspiration Toxicity • Genetic mutation • Birth defects or infertility • Hypersensitive nose, mouth, throat • Organ damage • Lung, nose and throat damage

45. Oxidizers • This symbol represents Oxidizers. • Oxidizers are chemicals that release large amounts of oxygen into the air. • Oxidizers tend to be corrosive– so wear PPE • They are also reactive– they react strongly with other products

46. Organic Peroxides You may have noticed that the Exploding Bomb pictogram uses the term “Organic Peroxides”. They are hazardous because they are: • Thermally unstable – (self heating) • Liable to explode • Burn rapidly • Explosives • Self-Reactives • Organic Peroxides • React dangerously with other substances • Are sensitive to impact or friction (think nitro glycerin explosives)

47. Oxidizers and Organic PeroxidesL VE toBURN!! They love starting fires and making them BIGGER… • Store them by themselves • Keep them away from flammables

48. GHS Pictograms Posters • Every TDI-Brooks vessel or facility should have a poster of the GHS pictograms posted in a central area near the SDS Binder. If your area does not have a poster, email a request for one to shannonsmith@tdi-bi.com. • There is a printable GHS symbols poster on the SDS page of the ship web pages • GHS symbols can also easily be found online with a simple search

49. How to detect a chemical • Smell is one of the main ways to detect if a chemical is present or is leaking from a container. • Most of you have found a broken bottle or spilled substance by smell before.

50. How to detect a chemical • Sometimes, detecting a spill is more obvious. • Sight is another way to detect if a chemical is present or is leaking from a container.