HOW TO MANAGE THE NEW HAZCOM STANDARD

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HOW TO MANAGE THE NEW HAZCOM STANDARD
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The Basics of the New HCS

• On March 26, 2012, OSHA issued its Hazard
  Communication Standard (HCS) to align with the
  Globally Harmonized System of Classification and
  Labeling of Chemicals (GHS).
• GHS, developed by the United Nations, is a global
  approach to classifying chemical hazards and
  providing information about those hazards via
  standardized labels and safety data sheets.
• OSHA is calling the revised standard HazCom
  2012 and it goes into effect May 25, 2012.
• Core responsibilities employers have to their
  employees remain the sameto keep them safe from
  chemical exposure. The tools they use to do that
  are just changing.
• According to Assistant Secretary David Michaels,
  OSHA's 1983 Hazard Communication Standard gave
  workers the right to know . . . this update will
  give them the right to understand.

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Benefits to companies

• A safer work environment and improved relations
  with employees,
• An increase in efficiency and reduced costs from
  compliance with hazard communication regulations,
• Application of expert systems resulting in
  maximizing expert resources and minimizing labor
  and costs,
• Facilitation of electronic transmission systems
  with international scope,
• Expanded use of training programs on health and
  safety,
• Reduced costs due to fewer accidents and
  illnesses,
• Improved corporate image and credibility.

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Benefits to workers and the public

• Improved safety for workers and others through
  consistent and simplified communications on
  chemical hazards and practices to follow for safe
  handling and use
• Greater awareness of hazards, resulting in safer
  use of chemicals in the workplace and in the home

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Employers Who Use Chemicals in The Workplace Will
Need To

• Train employees on new labeling system,
  pictograms, and SDS format (by 12/1/13).
• Ensure that only new format SDSs are maintained
  (by 6/1/15).
• Ensure that products are not received without new
  labels (by 12/1/15).
• Update your labeling system using the new GHS
  system (by 6/1/16).
• Update your Hazcom program to reflect changes (by
  6/1/16).
• Provide any additional training (such as updates
  to the Hazcom program-by 6/1/16).

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Manufacturers or Importers of Chemicals

• During the transition period to the effective
  completion dates noted in the standard (June 1,
  2015 and June 1, 2016), chemical manufacturers,
  importers, distributors and employers may comply
  with either 29 Code of Federal Regulations
  1910.1200 (the final standard), the current
  standard, or both.
• Ensure that chemicals are properly classified
  according to the revised standard (by 6/1/15).
• Prepare SDSs in proper format (by 6/1/15).
• Prepare updated labels (cannot ship with old
  labels after Dec. 1, 2015.)

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Major changes to the Hazard Communication Standard

• Hazard classification Provides specific criteria
  for classification of health and physical
  hazards, as well as classification of mixtures.
• 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.
• 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.

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The New Safety Data Sheets

• Formerly known as MSDS
• Uniform format by June 1, 2015 with 11 required
  sections

Section 1, Identification Section 2,
Hazard(s) Section 3, Composition/information on
ingredients Section 4, First-aid measures Section
5, Fire-fighting measures Section 6, Accidental
release measures Section 7, Handling and
storage Section 8, Exposure controls/personal
protection Section 9, Physical and chemical
properties. Section 10, Stability and
reactivity Section 11, Toxicological information
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The New Safety Data Sheets (cont.)

• Other sections on the new SDS
• Section 12, Ecological information
• Section 13, Disposal considerations
• Section 14, Transport information
• Section 15, Regulatory information
• Section 16, Other information, includes the date
  of preparation or last revision.
• Only 1 set of data sheets is required. May be a
  time where MSDSs/SDSs under both standards will
  be present in the workplace. This situation is
  acceptable to OSHA, and employers will not be
  required to maintain two sets of MSDSs/SDSs.
• Since other agencies regulate this information,
  OSHA will not enforce Sections 12 through 15
  however, the SDS must include at least the
  heading names for those sections.

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Hazard Communication Standard Label

• Labels will be required to have pictograms (to
  convey hazards about the chemical), a signal
  word, hazard and precautionary statements, the
  product identifier, and supplier identification.
• NFPA and HMIS labels are permitted however, the
  information provided must be consistent with the
  new HCS.

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Update Labels to GHS

• Current OSHA Template
• Identity of hazardous chemical
• Hazard warnings
• Contact information for manufacturer/importer/re
  sponsible party.
• GHS Template
• Product Identifier
• Pictograms
• Signal word
• Precautionary Statements
• Hazardous Statements
• Supplemental Information
• Supplier Identification

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Effective Dates for Compliance
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GHS Authoring Costs OSHA vs. Industry Analysis

• OSHAs Estimates
• 100 million in labor cost to revise 400,000
  MSDS to GHS format (OSHA concedes that it may be
  as high as 800,000)
• Average time of 5.14 hours to update each
  document
• 47 per hour labor rate
• This translates into roughly 250 per MSDS
• Industrys Estimates
• Consumer industrial paints 7 hours per SDS
  at cost of 750 minimum
• Global chemical manufacturer approx 8-20 hours
  per SDS at cost of 400-1,000
• Paint and coatings formulator 5 hours at cost
  of 300-1,000
• Global petrochemical manufacturer - 6 hours at
  cost of 375
• A Tale of Two Estimates
• OSHA 400K MSDS / 5.14 hours per doc / 250 per
  MSDS estimated total cost 100M
• Manufacturers gt400K MSDS / 9.2 hours per doc /
  gt600 per MSDS estimated total cost 250M

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Now What?

• Outline your compliance framework NOW,
  predetermining
• Roles and responsibilities at a corporate, site,
  field level
• of employees to be trained / estimated training
  hours required
• of work sites impacted
• of plant managers and safety professionals
  involved / estimated time requirement
• of product MSDS to be revised
• Develop a capacity plan to address the transition
  and all required changes.
• Conduct a resource assessment.
• Develop a draft training plan.
• Analyze required infrastructure revisions and
  upgrades
• Expanded data fields
• GHS symbols/pictograms
• New label templates for internal containers
• Analyze required internal process changes.
• Evaluate impact of GHS re-classification.
• Analyze and confirm vendor capabilities

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To learn more

• The GHS, in its entirety (including
  classification criteria and label and MSDS
  requirements), can be downloaded at
  http//www.unece.org/trans/danger/publi/ghs/ghs_re
  v03/03files_e.html
• OSHAs Notice of Proposed Rulemaking on the GHS
  is available at http//www.osha.gov/pls/oshaweb/o
  wadisp.show_document?p_tableFEDERAL_REGISTERp_id
  21110
• A 12-hour training course on the GHS is offered
  by the Society for Chemical Hazard Communication
  (SCHC) http//www.schc.org/training.php
• For information sheets on additional GHS topics
• OSHA site http//www.osha.gov/dcsp/alliances/schc
  /schc.htmldocuments - go to 'Products and
  Resources'.
• or SCHC site http//www.schc.org/issues.php?start
  _from5ucatarchivesubactionidcat9 -
  see 'GHS Information Sheets'.
• The OSHA Guide to the Globally Harmonized System
  of Classification and Labeling of Chemicals is
  available at http//www.osha.gov/dsg/hazcom/ghs.h
  tml