The GHS and OSHA Hazard Communication Virtual Summit Best Practices for Compliance and Implementation February 26, 2013 11:00 a.m. – 3:00 p.m. ET
The GHS and OSHA Hazard Communication Virtual Summit • Virtual Summit Technical Assistance • Call: 877-297-2901 • Email: firstname.lastname@example.org
The GHS and OSHA Hazard Communication Virtual Summit Session 1: 11:00 a.m. – 11:45 a.m. ET Build a Compliant and Best-in-Class Hazard Communication Program Tim Neubauer, CHST, MESH National Safety Council
What is the Globally Harmonized System? • The Globally Harmonized System (GHS) is an international approach to hazard communication, providing agreed criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets. • The GHS was negotiated in a multi-year process by hazard communication experts from many different countries, international organizations, and stakeholder groups. • It is based on major existing systems around the world, including OSHA's Hazard Communication Standard and the chemical classification and labeling systems of other US agencies.
What is the Globally Harmonized System? • The result of this negotiation process is the United Nations' document entitled "Globally Harmonized System of Classification and Labeling of Chemicals," commonly referred to as The Purple Book. • We will cover the harmonized classification criteria for health, physical, and environmental hazards of chemicals. • We will also cover the standardized label elements that are assigned to these hazard classes and categories, and provide the appropriate signal words, pictograms, and hazard and precautionary statements to convey the hazards to users. • A standardized order of information for safety data sheets will also be reviewed.
Why did OSHA decide to adopt the GHS? • OSHA has modified the Hazard Communication Standard (HCS) to adopt the GHS to improve safety and health of workers through more effective communications on chemical hazards. • Since 1983, the HCS has provided employers and employees extensive information about the chemicals in their workplaces. • The original standard is performance-oriented, allowing chemical manufacturers and importers to convey information on labels and material safety data sheets in whatever format they choose. • A GHS standardized approach to classifying the hazards and conveying information will be more effective.
Why did OSHA decide to adopt the GHS? • The GHS provides a standardized approach, including detailed criteria for determining what hazardous effects a chemical poses, as well as standardized label elements assigned by hazard class and category. • This will enhance both employer and worker comprehension of hazards. • In addition, the safety data sheet requirements establish an order of information that is standardized.
Why did OSHA decide to adopt the GHS? • Adoption of the GHS in the US and around the world will also help to improve information received from other countries—since the US is both a major importer and exporter of chemicals. • Currently, labels and safety data sheets may include symbols and hazard statements that are unfamiliar to readers or not well understood. • Also Containers may be labeled with such a large volume of information that important statements are not easily recognized. • Given those differences in hazard classification criteria, labels may also be incorrect when used in other countries. • Adopting the GHS, will minimize these problems and chemicals crossing borders will have consistent information, thus improving communication globally.
Phase-in period for the revised Hazard Communication Standard *This date coincides with the EU implementation date for classification of mixtures
Phase-in Period • During the phase-in period, employers would be required to be in compliance with either the existing HCS or the revised HCS, or both. OSHA recognizes that hazard communication programs will go through a period of time where labels and SDSs under both standards will be present in the workplace. This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.
Training Compliance Effective Date • OSHA is requiring that employees are trained on the new label elements (i.e., pictograms, hazard statements, precautionary statements, and signal words) and SDS format by December 1, 2013, while full compliance with the final rule will begin in 2015. • OSHA believes that American workplaces will soon begin to receive labels and SDSs that are consistent with the GHS, since many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDSs. • It is important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they will be familiar with them, understand how to use them, and access the information effectively. • For more information, http://www.osha.gov/dsg/hazcom/effectivedates.html.
Major changes to the Hazard Communication Standard • The three major areas of change are: • Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result. • Labels: 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.
Major changes to the Hazard Communication Standard • The GHS does not include harmonized training provisions, but recognizes that training is essential to an effective hazard communication approach. • The revised Hazard Communication Standard (HCS) requires that workers be re- trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safety data sheets. • For a side-by-side comparison of the current HCS and the final revised HCS please see OSHA's hazard communication safety and health topics webpage at: http://www.osha.gov/dsg/hazcom/index.html
Some Hazard Communication Standard Provisions Remain Unchanged • The revised Hazard Communication Standard (HCS) is a modification to the existing standard. • The parts of the standard that did not relate to the GHS (such as the basic framework, scope, and exemptions) remained largely unchanged. • There have been some modifications to terminology in order to align the revised HCS with language used in the GHS. For example, the term "hazard determination" has been changed to "hazard classification" and "material safety data sheet" was changed to "safety data sheet."
Labels changes under the revised Hazard Communication Standard • The current Hazard Communication Standard (HCS), states a label preparer must provide the identity of the chemical, and the appropriate hazard warnings. This may be done in a variety of ways, and the method to convey the information is left to the preparer. Under the revised HCS, once the hazard classification is completed, the standard specifies what information is to be provided for each hazard class and category. Labels will require the following elements:
Labels changes under the revised Hazard Communication Standard • Pictogram: 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. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the HCS. • Signal words: a single 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 are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards. • Hazard Statement: 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. • Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical.
Pictograms • There are nine pictograms under the GHS to convey the health, physical and environmental hazards. • The final Hazard Communication Standard (HCS) requires eight of these pictograms, the exception being the environmental pictogram, as environmental hazards are not within OSHA's jurisdiction.
Health Hazards • Carcinogen• Mutagenicity• Reproductive Toxicity• Respiratory Sensitizer• Target Organ Toxicity• Aspiration Toxicity
Flame • Flammables • Pyrophorics • Self-Heating • Emits Flammable Gas • Self-Reactives • Organic Peroxides
Exclamation Mark • Irritant (skin and eye) • Skin Sensitizer • Acute Toxicity (harmful) • Narcotic Effects • Respiratory Tract Irritant • Hazardous to Ozone Layer(Non Mandatory)
Gas Cylinder • Gases under Pressure
Corrosion • Skin Corrosion/ burns • Eye Damage • Corrosive to Metals
Exploding Bomb • Explosives • Self-Reactives • Organic Peroxides
Flame over Circle • Oxidizers
Environment(Non Mandatory) • Aquatic Toxicity
Skull and Crossbones • Acute Toxicity (fatal or toxic)
Label Information • In the revised Hazard Communication Standard (HCS), OSHA is lifting the stay on enforcement regarding the provision to update labels when new information on hazards becomes available. • Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information. • If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.
Hazards covered under the current Hazard Communication Standard that have not been addressed by the GHS • In the final HCS, HNOC hazards will not be required to be disclosed on the label but will be required to be disclosed in section 2 of the Safety Data Sheet (SDS). This reflects how GHS recommends these hazards should be disclosed. • Chemical manufacturers and importers are expected to assess these hazards when they are conducting their hazard evaluation of physical and health hazards. • A new or separate evaluation is not required.
Benefits of GHS • OSHA expects that the modifications to the Hazard Communication Standard (HCS) will result in increased safety and health for the affected employees and reduce the numbers of incidents, fatalities, injuries, and illnesses associated with exposures to hazardous chemicals. • The GHS revisions to the HCS standard for labeling and safety data sheets would enable employees exposed to workplace chemicals to more quickly obtain and to more easily understand information about the hazards associated with those chemicals. • In addition, the revisions to HCS are expected to improve the use of appropriate exposure controls and work practices that can reduce the safety and health risks associated with exposure to hazardous chemicals.
United Nations revises the GHS every two years. • GHS will be a living document and is expected to remain up-to-date and relevant; therefore further changes may be adopted on a two year cycle. • Presently most of the recent updates have been clarification of text. • However, OSHA anticipates that future updates of the Hazard Communication Standard (HCS) may be necessary and can be done through various rulemaking options, including: • Technical updates for minor terminology changes, • Direct Final Rules for text clarification, and • Notice and Comment rulemaking for more substantive or controversial updates such as additional criteria or changes in health or safety hazard classes or categories.
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The GHS and OSHA Hazard Communication Virtual Summit Short Conference Break 11:45 a.m. – 12:00 p.m. ET Please stay logged in during the break
The GHS and OSHA Hazard Communication Virtual Summit Session 2: 12:00 p.m. – 1:00 p.m. ET How the New GHS Impacts the OSHA HazCom Standard Tim Neubauer, CHST, MESH National Safety Council
What are the Major Changes to the Hazard Communication Standard? The three major areas of change are in hazard classification, labels, and safety data sheets: • Hazard classification: The definitions of hazard have been chanted to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result
What are the Major Changes to the Hazard Communication Standard? (cont’d) • Labels: 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.
Comparison • The HCS 2012 is written as a modification to the existing standard, and those parts of the standard that do not relate to the GHS, or are already consistent with it remain unchanged. • Additionally, some minor changes to terminology have been made in order to align this rule with language used in the GHS. For example, the term "hazard determination" has been changed to "hazard classification" and "material safety data sheet" has been changed to "safety data sheet."
Global Word/Definition Changes • To stream line this presentation, we will not discus those definitions and minor word changes like “the/these,” etc. • The term “evaluated” is now “classified” • The term “element” is now “substance” • The term “specific chemical identity” is now “trade secret”
(a) Purpose. • (a)(1) The purpose of this section is to ensure that the hazards of all chemicals produced or imported are classifiedevaluated, and that information concerning therclassified hazards is transmitted to employers and employees. The requirements of this section are intended to be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 3.Theis transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheetsafety data sheets and employee training.
(a) Purpose. • (a)(2) This occupational safety and health standard is intended to address comprehensively the issue of classifyingevaluating the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, and to preempt any legislative or regulatory enactmentsal requirements of a state, or political subdivision of a state, pertaining to this subject. ClassifyingEvaluating the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, may include, for example, but is not limited to, provisions for: developing and maintaining a written hazard communication program for the workplace, including lists of hazardous chemicals present; labeling of containers of chemicals in the workplace, as well as of containers of chemicals being shipped to other workplaces; preparation and distribution of material safety data sheetsafety data sheets to employees and downstream employers; and development and implementation of employee training programs regarding hazards of chemicals and protective measures. Under section 18 of the Act, no state or political subdivision of a state may adopt or enforce, through any court or agency, any requirement relating to the issue addressed by this Federal standard, except pursuant to a Federally-approved state plan.
(b) Scope and application. • (b)(5) This section does not require labeling of the following chemicals: • (iv) Any distilled spirits (beverage alcohols), wine, or malt beverage intended for nonindustrial use, as such terms are defined in the Federal Alcohol Administration Act (27 U.S.C. 201 et seq.) and regulations issued under that Act, when subject to the labeling requirements of that Act and labeling regulations issued under that Act by the Bureau of Alcohol, Tobacco, and Firearmsand Explosives;
(c) Definitions. • "Classification" means to identify the relevant data regarding the hazards of a chemical; review those data to ascertain the hazards associated with the chemical; and decide whether the chemical will be classified as hazardous according to the definition of hazardous chemical in this section. In addition, classification for health and physical hazards includes the determination of the degree of hazard, where appropriate, by comparing the data with the criteria for health and physical hazards. • "Combustible liquid" means any liquid having a flashpoint at or above 100 deg. F (37.8 deg. C), but below 200 deg. F (93.3 deg. C), except any mixture having components with flashpoints of 200 deg. F (93.3 deg. C), or higher, the total volume of which make up 99 percent or more of the total volume of the mixture.
(c) Definitions. • "Compressed gas" means: • (i) A gas or mixture of gases having, in a container, an absolute pressure exceeding 40 psi at 70 deg. F (21.1 deg. C); or • (ii) A gas or mixture of gases having, in a container, an absolute pressure exceeding 104 psi at 130 deg. F (54.4 deg. C) regardless of the pressure at 70 deg. F (21.1 deg. C); or • (iii) A liquid having a vapor pressure exceeding 40 psi at 100 deg. F (37.8 deg. C) as determined by ASTM D-323-72.
(c) Definitions. • "Explosive" means a chemical that causes a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature.
(c) Definitions. • "Flammable" means a chemical that falls into one of the following categories: • (i) "Aerosol, flammable" means an aerosol that, when tested by the method described in 16 CFR 1500.45, yields a flame projection exceeding 18 inches at full valve opening, or a flashback (a flame extending back to the valve) at any degree of valve opening;
(c) Definitions. • (ii) "Gas, flammable" means: • (A) A gas that, at ambient temperature and pressure, forms a flammable mixture with air at a concentration of thirteen (13) percent by volume or less; or • (B) A gas that, at ambient temperature and pressure, forms a range of flammable mixtures with air wider than twelve (12) percent by volume, regardless of the lower limit;
(c) Definitions. • (iii) "Liquid, flammable" means any liquid having a flashpoint below 100 deg. F (37.8 deg. C), except any mixture having components with flashpoints of 100 deg. F (37.8 deg. C) or higher, the total of which make up 99 percent or more of the total volume of the mixture. • (iv) "Solid, flammable" means a solid, other than a blasting agent or explosive as defined in 1910.109(a), that is liable to cause fire through friction, absorption of moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious hazard. A chemical shall be considered to be a flammable solid if, when tested by the method described in 16 CFR 1500.44, it ignites and burns with a self-sustained flame at a rate greater than one-tenth of an inch per second along its major axis.
(c) Definitions. • "Flashpoint" means the minimum temperature at which a liquid gives off a vapor in sufficient concentration to ignite when tested as follows: • (i) Tagliabue Closed Tester (See American National Standard Method of Test for Flash Point by Tag Closed Tester, Z11.24-1979 (ASTM D 56-79)) for liquids with a viscosity of less than 45 Saybolt Universal Seconds (SUS) at 100 deg. F (37.8 deg. C), that do not contain suspended solids and do not have a tendency to form a surface film under test; or • (ii) Pensky-Martens Closed Tester (see American National Standard Method of Test for Flash Point by Pensky-Martens Closed Tester, Z11.7-1979 (ASTM D 93-79)) for liquids with a viscosity equal to or greater than 45 SUS at 100 deg. F (37.8 deg. C), or that contain suspended solids, or that have a tendency to form a surface film under test; or
(c) Definitions. • (iii) Setaflash Closed Tester (see American National Standard Method of Test for Flash Point by Setaflash Closed Tester (ASTM D 3278-78)). • Organic peroxides, which undergo autoaccelerating thermal decomposition, are excluded from any of the flashpoint determination methods specified above.
(c) Definitions. • "Hazard category" means the division of criteria within each hazard class, e.g., oral acute toxicity and flammable liquids include four hazard categories. These categories compare hazard severity within a hazard class and should not be taken as a comparison of hazard categories more generally. • "Hazard class" means the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute toxicity. • "Hazard not otherwise classified (HNOC)" means an adverse physical or health effect identified through evaluation of scientific evidence during the classification process that does not meet the specified criteria for the physical and health hazard classes addressed in this section. This does not extend coverage to adverse physical and health effects for which there is a hazard class addressed in this section, but the effect either falls below the cut-off value/concentration limit of the hazard class or is under a GHS hazard category that has not been adopted by OSHA (e.g., acute toxicity Category 5).