Hazard Communication (HazComm2012) and the Globally Harmonized System (GHS)

1
Hazard Communication (HazComm2012) and the
Globally Harmonized System (GHS)

• Mark Banden
• Compliance Assistance Specialist
• OSHA, Kansas City Area Office

2
Plan For the DayHazard Communication (HazComm
2012) and the Globally Harmonized System (GHS)  

• Brief overview of the GHS
• Benefits of revising the Hazard Communication
  Standard to adopt the GHS
• Overview of some major changes to the HCS
• Detailed Side-By-Side Review of Changes
• Employee Training Program Example
• References

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Globally Harmonized System of Classification and
Labeling of Chemical - GHS

• An Internationally common, coherent approach to
  classifying and communicating chemical hazards

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What is GHS?

• UN system developed to standardize the
  classification of chemicals and communication of
  hazards.
• Revised every 2 years. Also known as the Purple
  Book. GHS (Rev.3) (2009) UNECE.
• Already adopted in Europe and many other
  countries (China, Japan, New Zealand, Brazil,
  etc.).
• GHS framework uses a building block approach
• countries implement standardized elements they
  want
• still have minor variations, but much less than
  in the past
• Intended to facilitate international trade and
  improve the quality and consistency of hazard
  information provided.

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GHS

• Harmonizes classification, Safety Data Sheets
  (SDS) and labeling
• Not a model regulation contains criteria and
  text
• Specification versus Performance Oriented
  Approach
• Created as a building-block approach
• Each competent authority adopts those provisions
  applicable to sphere of regulation or need
• Covers physical, health and environmental hazards
• OSHA Standard Maintains current exceptions to
  coverage
• Biological Agents
• Radioactive elements
• Consumer Products
• Hazardous Waste
• Etc..

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OSHA and the GHS

• OSHAs 1983 final HCS included recognition of the
  importance of international harmonization of such
  requirements, and a commitment to work towards an
  international approach
• The Agency
• Supported adoption of the international mandate
  to develop the GHS
• Helped to negotiate the provisions of the GHS
  and
• Leads the current US delegation to the United
  Nations Committee and Subcommittee on the GHS

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ModifiedHazard Communication Standard(HazComm
2012)
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Rulemaking History

• OSHA published an advance notice of proposed
  rulemaking (ANPR) on September 12, 2006
• The ANPR described OSHAs plan to apply the GHS
  to the HCS comments were received from over 100
  respondents
• OSHA published a notice of proposed rulemaking on
  September 29, 2009, that provided a preamble
  explanation, as well as the text of the proposed
  modifications

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Rulemaking History, cont.

• The NPRM established a 90-day period for written
  comments
• Public hearings were convened in Washington, DC,
  and Pittsburgh, Pennsylvania, to receive oral
  testimony
• A period for post-hearing comments and briefs was
  established by the Administrative Law Judge
• When the public record was completed, OSHA
  prepared the final rule based on the record,
  along with various analyses required for such
  standards
• The final rule was published in the Federal
  Register on March 26, 2012 (77 FR 17574 17896)
• The rule will be in effect 60 days later May 25,
  2012

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Site visits Stakeholder meetings RFI or ANPR
SBREFA
Public Comment
Implementation
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Why Adopt the GHS?

• The primary purpose of the HCS is to reduce
  chemical source illnesses and injuries
• Since the HCS was promulgated in 1983, acute
  illnesses and injuries from chemicals have
  decreased 42
• However, there is still a critical need for
  effective information to protect exposed workers
  from chemicalsparticularly from chronic effects

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Why Adopt the GHS, cont.

• A key part of the new approach is increased
  comprehensibility due to the standardized or
  harmonized approach to information dissemination
• Standardized Information includes
• SDS
• Labels

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Benefits

• Enhance worker comprehension of hazards,
• especially for low and limited-literacy workers,
• reduce confusion in the workplace,
• facilitate safety training,
• result in safer handling and use of chemicals
• Provide workers quicker and more efficient access
  to information on the safety data sheets
  (emergency sections are always 4, 5, 6)
• Result in cost savings to American businesses in
  productivity improvements, fewer safety data
  sheet and label updates and simpler new hazard
  communication training and
• Reduce trade barriers by harmonizing with systems
  around the world.

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Whats the Impact?

• Rule will impact over 5 million workplaces, and
  43 million workers
• 650,000 Chemicals used in the USA
• Annualized savings for employers of between 585
  mil and 798 mil
• Most of this through increased productivity for
  HS managers and logistics personnel
• Expect 500 workplace injuries and 43 fatalities
  to be prevented annually as a result of change
• Savings attributed to uniform SDSs and labels
  accounts for between 16 mil and 32.2 mil

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Penalties for non-compliance are very real

• In 2009 2010 combined, OSHA cited over 13,000
  instances of HCS violations in workplaces across
  the United States
• 3 on OSHA's top 10 list of most frequently
  violated compliance standards

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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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Principles Assumptions

• OSHA has modified only the provisions of the HCS
  that must be changed to align with the GHS
• The basic framework of the HCS remains the same
• Chemical manufacturers and importers are
  responsible for providing information about the
  identities and hazards of chemicals they produce
  or import
• All employers with hazardous chemicals in their
  workplaces are still required to have a hazard
  communication program, and provide information to
  employees about their hazards and associated
  protective measures
• OSHA has maintained or enhanced the overall
  current level of protection of the HCS

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Principles Assumptions, cont.

• Other aspects of the standard have minimal
  modifications in terminology to make them
  consistent with GHS.
• The scope and application is basically unchanged,
  maintaining practical accommodations made by OSHA
  
• Written hazard communication program
  requirements, worker training, and trade secret
  provisions are all largely unchanged from the
  existing rule

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Other Aspects of the Approach

• Maintain consistency with major trading partners
  where possible
• Revise other OSHA standards that will be affected
  by the changes to the HCS
• Minimize country-specific deviations to be as
  harmonized as possible with GHS provisions

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Organization of the Final Rule

• Keep the regulatory text as simple as possible,
  adding the detailed specification requirements to
  Appendices
• Employers who do not have to classify hazards or
  prepare labels and safety data sheets (SDSs) do
  not need to access or be familiar with much of
  the new text

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Organization of the Final Rule

• (a) Purpose
• (b) Scope and Application
• (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
• Appendices A -F

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Appendices

• Appendix A, Health Hazard Criteria (Mandatory)
  (NEW)
• Appendix B, Physical Hazard Criteria (Mandatory)
  (NEW)
• Appendix C, Allocation of Label Elements
  (Mandatory) (NEW)
• Appendix D, Safety Data Sheets (Mandatory) (NEW)
• Appendix E, Definition of Trade Secret
  (Mandatory)
• Appendix F, Guidance For Carcinogenicity(Non-Manda
  tory) (NEW)

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Side-by-Side Comparison Of Changes HazComm 1994
versus HazComm 2012
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a) Purpose

• HazCom 1994

• HazCom 2012

• All hazards to be classified
• Other provisions the same, except OSHA added that
  the rule is consistent with Revision 3 of the GHS
  (2009 Version)
• Slight clarifying modification was made to the
  language regarding preemption
• Federalism

• All hazards to be evaluated
• Comprehensive hazard communication program to
  transmit information
• Preempt state laws

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Federalism

• 1910.1200(a)(2) This occupational safety and
  health standard is intended to address
  comprehensively the issue of classifying the
  potential hazards of chemicals, and communicating
  information concerning hazards and appropriate
  protective measures to employees, and to preempt
  any legislative or regulatory enactments of a
  state, or political subdivision of a state,
  pertaining to this subject. Under section 18 of
  the Act, no state or political subdivision of a
  state may adopt or enforce any requirement
  relating to the issue addressed by this Federal
  standard, except pursuant to a Federally-approved
  state plan.

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b) Scope and Application

• HazCom 2012

• HazCom 1994

• All chemicals known to be present are covered
• Practical accommodations for special situations
• Addresses interface with other Federal laws

• Minimal changes except to conform terminology,
  and remove reference to current Appendix E which
  has been deleted from the standard.

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c) Definitions

• HazCom 1994

• HazCom 2012

• Physical hazard definitions removed from
  paragraph (c), and placed in a new Appendix B on
  physical hazard classification criteria
• Following terms are also deleted flashpoint
  (methods included in Appendix B), hazard warning,
  material safety data sheets
• Some definitions are revised to be
  GHS-consistent,
• New definitions added for classification

• Includes specific definitions for terms used in
  the standard, as well as all physical hazards

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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

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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
• These terms are primarily related to the changes
  in approach to evaluating hazards, and providing
  label /SDS information

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GHS New Terms

• Classification identification and evaluation of
  relevant data regarding chemical hazards and
  comparison to GHS criteria
• Hazard class the nature of the physical or
  health hazard
• Hazard category division of criteria within
  each hazard class
• Hazard statement statement assigned to a hazard
  class and category that describes the nature and
  degree of hazard
• Pictogram symbol plus other graphic elements
  intended to convey specific information about the
  hazards
• Precautionary statement phrase that describes
  measures that should be taken to minimize or
  prevent adverse effects
• Safety data sheet (SDS) Material Safety Data
  Sheet (MSDS)
• Signal word indicates the relative level of
  severity of hazard. Danger is more severe.
  Warning is less severe.

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Definition of hazardous chemical

• 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 used the building block GHS concept to
  include
• a simple asphyxiant,
• combustible dust,
• pyrophoric gas, or
• hazard not otherwise classified.

ADDED BY OSHA
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Definitions

• Hazards Not Otherwise Classified
• Classification identifies a hazard, but the
  evidence does not meet the currently specified
  criteria covered by HazComm 2012
• Example Static Accumulator, Magnetic,
  etc.. Example Toxic at less than 1
  concentration

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d) Hazard Classification

• HazCom 2012

• HazCom 1994

• Performance-oriented
• Definitions in paragraph (c), Appendices A and B
• Appendix Bparameters for evaluating data
• Floor of chemicals considered hazardous
• One study rule
• Standardized mixture cut-off rules

• Specific and detailed
• Concept of classification vs. determination in
  current rule
• Each hazard class has detailed criteria to apply
  to data on the chemical
• No floor based on weight of evidence
• Mixture rules are specific to each hazard class

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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
• Placing a chemical into a hazard class , and
  where necessary, a hazard category, is the
  concept of classification determining not only
  the hazard, but also the severity of the effect

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Hazard Classification
Hazard Classification
Hazard Type
Hazard Class
Hazard Severity
Hazard Category
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GHS Hazard Classes

• Physical
• Explosives
• Flammable gases
• Aerosols
• Oxidizing gases
• Gases under pressure
• Flammable liquids
• Flammable solids
• Self-reactive substances and mixtures
• Pyrophoric liquids
• Pyrophoric solids
• Self-heating substances and mixtures
• Substances and mixtures which in contact with
  water emit flammable gases
• Oxidizing liquids
• Oxidizing solids
• Organic peroxides
• Corrosive to metals

• Health
• Acute toxicity
• Skin corrosion/irritation
• Serious eye damage/irritation
• Respiratory or skin sensitization
• Germ cell mutagenicity
• Carcinogenicity
• Reproductive toxicity
• Specific target organ toxicity (STOT SE) single
  exposure
• Specific target organ toxicity (STOT RE)
  repeated exposure
• Aspiration hazard
• Environmental
• Hazardous to the aquatic environment
• Hazardous to the ozone layer

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HazComm2012 GHS Hazard Classes

• Physical
• Explosives
• Flammable gases
• Aerosols
• Oxidizing gases
• Gases under pressure
• Flammable liquids
• Flammable solids
• Self-reactive substances and mixtures
• Pyrophoric liquids
• Pyrophoric solids
• Self-heating substances and mixtures
• Substances and mixtures which in contact with
  water emit flammable gases
• Oxidizing liquids
• Oxidizing solids
• Organic peroxides
• Corrosive to metals
• Pyrophoric Gases
• Combustible Dust

• Health
• Acute toxicity
• Skin corrosion/irritation
• Serious eye damage/irritation
• Respiratory or skin sensitization
• Germ cell mutagenicity
• Carcinogenicity
• Reproductive toxicity
• Specific target organ toxicity (STOT SE) single
  exposure
• Specific target organ toxicity (STOT RE)
  repeated exposure
• Aspiration hazard
• Simple Asphyxiant
• Environmental
• Hazardous to the aquatic environment
• Hazardous to the ozone layer
• Hazards Not Elsewhere Classified

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Hazard Classification

• Manufacturers are still responsible for
  determining the hazards of the chemicals they
  produce or import
• Classification (similar to hazard determination)
  is based on the full range of available
  information.
• The procedures for determining if the
  manufacturer has properly performed the hazard
  classification are provided in Appendix A
  (health) and Appendix B (physical)
• Single Study must be used for classification of
  Carcinogens

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Health Hazards(Appendix A)
Removed Category 5
Hazard Class Hazard Category Hazard Category Hazard Category Hazard Category
Acute Toxicity 1 2 3 4
Skin Corrosion/Irritation 1A 1B 1C 2
Serious Eye Damage/ Eye Irritation 1 2A 2B
Respiratory or Skin Sensitization 1
Germ Cell Mutagenicity 1A 1B 2
Carcinogenicity 1A 1B 2
Reproductive Toxicity 1A 1B 2 Lactation
STOT Single Exposure 1 2 3
STOT Repeated Exposure 1 2
Aspiration 1
Simple Asphyxiants Single Category Single Category
OSHA Addition
39
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Hazard Categories

• Each hazard class has one or more categories of
  hazard, based on severity,
• eg.Acute Toxicity Oral

LD50 (mg/kg body weight) 5 5 lt LD50 50 50 lt LD50 300 300 lt LD50 2000 2000 lt LD50 5000
GHS Hazard Category Category 1 Category 2 Category 3 Category 4 Category 5
Appendix A used to determine Category for health
hazards
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Acute Toxicity Oral
LD50 (mg/kg body weight) 5 5 lt LD50 50 50 lt LD50 300 300 lt LD50 2000 2000 lt LD50 5000
GHS Hazard Category Category 1 Category 2 Category 3 Category 4 Category 5
GHSLabel Danger Fatal if swallowed Danger Fatal if swallowed Danger Toxic if swallowed Warning Harmful if swallowed No symbol Warning May be harmful if swallowed
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43
Current HCS vs. HazCom 2012
HCS Corrosive definition
GHS definition/criteria of skin Corrosive
A.2.1.1 Skin corrosion is the production of
irreversible damage to the skin namely, visible
necrosis through the epidermis and into the
dermis, following the application of a test
substance for up to 4 hours. .Corrosive reactions
are typified by ulcers, bleeding, bloody scabs,
and, by the end of observation at 14 days, by
discoloration due to blanching of the skin,
complete areas of alopecia, and scars.
Histopathology should be considered to evaluate
questionable lesions.

• "Corrosive" A chemical that causes visible
  destruction of, or irreversible alterations in,
  living tissue by chemical action at the site of
  contact. For example, a chemical is considered to
  be corrosive if, when tested on the intact skin
  of albino rabbits by the method described by the
  U.S. Department of Transportation in appendix A
  to 49 CFR part 173, it destroys or changes
  irreversibly the structure of the tissue at the
  site of contact following an exposure period of
  four hours. This term shall not refer to action
  on inanimate surfaces.

Category 1 Corrosive Corrosive sub-categories Corrosive in ? 1 of 3 animals Corrosive in ? 1 of 3 animals
Exposure Observation
1A ? 3 min ? 1 h
1B gt 3 min ? 1 h ? 14 days
1C gt 1 h ? 4 h ? 14 days
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Health Hazards, cont.

• For carcinogens - OSHA is allowing classifiers
  to use determinations of IARC/NTP for
  classification instead of performing their own
  hazard evaluation
• New Appendix F
• Single Study positive findings must be reported
• -Where the weight of evidence for the
  carcinogenicity of a substance does not meet the
  above criteria, any positive study conducted in
  accordance with established scientific
  principles, and which reports statistically
  significant findings regarding the carcinogenic
  potential of the substance, must be noted on the
  safety data sheet.

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Physical Hazards(Appendix B)
ADDED BY OSHA
ADDED BY OSHA
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Significant OSHA Decisions

• The addition of Pyrophoric gas, Simple
  Asphyxiants and Combustible dust to the Physical
  and Health hazards is very significant as these
  are not hazards as defined by GHS

48
Hazards not Otherwise Classified

• One unique aspect to the OSHAs final rule is the
  definition of hazards not otherwise classified
  (HNOC)
• This definition was added to ensure that hazards
  currently covered by HCS continue to be covered
• Combustible Dust has its own hazard class
• Nanomaterials?
• Emerging Hazards.

49
Hazards not Otherwise Classified

• 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 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 been adopted by OSHA
  (e.g., acute toxicity Category 5, simple
  asphyxiant).

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Hazards not Otherwise Classified

• 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

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Simple Asphyxiant and Pyrophoric Gas

• Simple asphyxiant means a substance or mixture
  that displaces oxygen in the ambient atmosphere,
  and can thus cause oxygen deprivation in those
  who are exposed, leading to unconsciousness and
  death.
• Label Warning. May displace oxygen and cause
  rapid suffocation.
• Pyrophoric gas means a chemical in a gaseous
  state that will ignite spontaneously in air at a
  temperature of 130 degrees F (54.4 degrees C) or
  below.
• Label Danger. Catches fire spontaneously if
  exposed to air.

52
Combustible Dust

• Combustible dust is covered separately from HNOC,
  but is not specifically defined
• Guidance for defining combustible dust is to be
  taken from existing documents, including the
  directive for the National Emphasis Program the
  NFPA standards also provide useful information
• Combustible dust must be addressed on labels
  where appropriate
• Warning. May form combustible dust
  concentrations in air.
• Paragraph (f)(4) may apply to materials shipped
  in solid form, that create combustible dust when
  processed

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Mixtures

• HCS 2012 has a tiered approach to mixtures, with
  each health hazard class having a specific
  approach
• Step 1 Use available test data on the mixture
  as a whole to classify the mixture based on the
  substance criteria
• Step 2 Use bridging principles to extrapolate
  from other data (e.g., dilution principle)
• Step 3 Estimate hazards based on known
  information regarding the ingredients of the
  mixture (cut-offs may be applied)
• Chemical manufacturers and importers may rely on
  the information provided in ingredient SDSs
  unless they have a reason to know that it is
  inaccurate

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Cut off values/Concentration limits for health
and environmental hazard class
55
Tiered Approach to Classification

• Generally use test data for the mixture, when
  available
• ?
• Use bridging principles, if applicable
• ?
• For health and environmental hazards, estimate
  hazards based on the known ingredient information
  

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f) Labels and Other Forms of Warning

• HazCom 1994

• HazCom 2012

• Shipped containers to be labeled with product
  identifier signal word hazard statement(s)
  pictograms precautionary statements and
  responsible party
• Specifies information by hazard class and
  category

• Shipped containers to be labeled with identity,
  appropriate hazard warnings, and responsible
  party
• Performance-oriented, specifics left to
  discretion of chemical manufacturer or importer

57
Approach to Labels

• The final rulelike the GHSis a specification
  approach to labels.
• In Appendix C, OSHA has indicated by hazard class
  and hazard category the label elements that must
  be on the label
• Appendix C is basically a cookbook approach to
  labeling
• Once classification of the hazards is completed,
  Appendix C is to be consulted to determine how to
  convey the required information

58
Label Requirements for Shipped Containers

1. Product identifier
2. Signal word
3. Hazard statement(s)
4. Pictogram(s)
5. Precautionary statement(s)
6. Name, address, and phone number of the
   responsible party

59

60
Precedence of hazard
gt
gt
Skin/Eye irritation
Skin/Eye irritation
gt
gt
DANGER
WARNING
61
Red vs. Black Borders

• The GHS allows competent authorities to use only
  black borders on pictograms for domestic
  shipments
• OSHA is requiring red borders regardless of the
  shipments destination
• The red borders increase comprehensibility
• The requirement for red borders will result in
  additional options being developed to comply for
  example, new printers are becoming available for
  this requirement
• Blank red diamonds are not permitted on a label

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Signal Word Hazard Statements
63
Signal Word

• Danger or Warning
• Danger is more hazardous
• Used to emphasis hazard and to discriminate
  between hazard categories (level of hazard)
• e.g. Acute toxicity category 1 will require
  Danger, category 4 will require Warning

64
Hazard Statements

• Dictated by Appendix C

C.4 REQUIREMENTS FOR SIGNAL WORDS, HAZARD STATEMENTS, PICTOGRAMS, AND PRECAUTIONARY STATEMENTS C.4.1 ACUTE TOXICITY ORAL(Classified in Accordance with Appendix A.1) C.4 REQUIREMENTS FOR SIGNAL WORDS, HAZARD STATEMENTS, PICTOGRAMS, AND PRECAUTIONARY STATEMENTS C.4.1 ACUTE TOXICITY ORAL(Classified in Accordance with Appendix A.1) C.4 REQUIREMENTS FOR SIGNAL WORDS, HAZARD STATEMENTS, PICTOGRAMS, AND PRECAUTIONARY STATEMENTS C.4.1 ACUTE TOXICITY ORAL(Classified in Accordance with Appendix A.1) C.4 REQUIREMENTS FOR SIGNAL WORDS, HAZARD STATEMENTS, PICTOGRAMS, AND PRECAUTIONARY STATEMENTS C.4.1 ACUTE TOXICITY ORAL(Classified in Accordance with Appendix A.1)
PictogramSkull and crossbones
Hazard category Signal word Hazard statement
1 Danger Fatal if swallowed
2 Danger Fatal if swallowed
65
Hazard Statements

• A single harmonised hazard statement for each
  hazard category within each hazard class

e.g. Flammable liquid - Category 1
Extremely flammable liquid and vapour
- Category 2 Highly flammable
liquid and vapour - Category 3
Flammable liquid and vapour -
Category 4 Combustible liquid
66
Hazard Statements (cont.)

• e.g. Oral Acute Toxicity
• Category 1
• Fatal if swallowed
• Category 2
• Fatal if swallowed
• Category 3
• Toxic if swallowed
• Category 4
• Harmful if swallowed
• Category 5
• Maybe harmful if swallowed

67
Precautionary Information

• GHS label should include appropriate
  precautionary information.
• The GHS document includes examples of
  precautionary statements which can be used.
• The intent is to harmonize precautionary
  statements.
• There are four types of precautionary statements
  presented,
• "prevention,"
• "response,"
• "storage," and
• "disposal."

68
Precautionary InformationExample
Precautionary statements Precautionary statements Precautionary statements Precautionary statements
Prevention Response Storage Disposal
Wash thoroughly after handling. Chemical manufacturer, importer, or distributor to specify parts of the body to be washed after handling. Do not eat, drink or smoke when using this product. If swallowed Immediately call a poison center/doctor/ Chemical manufacturer, importer,or distributor to specify the appropriate source of emergency medical advice. Specific treatment (see on this label) Reference to supplemental first aid instruction. - if immediate administration of antidote is required. Rinse mouth. Store locked up. Dispose of contents/container to ... in accordance with local/regional/national/international regulations (to be specified).
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Examples of Precautionary Pictograms (Not
Mandatory)
70
Label Example
HazCom 2012 Minimum Requirements
HazCom 1994 Minimum requirements

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New Label Requirements
GHS Label
Workplace Label
XYZ Chemical, 234 E. 3rd St Murray KY 42071
227.777.6565

• Updated OSHA GHS Standard
• Product identifier
• Signal word
• Hazard statements
• Precautionary statements
• Pictograms
• Supplier information
• Supplemental information

XYZ Chemical, 234 E. 3rd St Murray KY 42071
227.777.6565

• Current OSHA Standard
• Material identity
• Hazard warnings
• Supplier information

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75
GHS Label-Bad Example-Toxic?
76
Updating Labels

• OSHA proposed to require labels to be updated
  within three months of getting new and
  significant information about the hazards
• The final rule requires containers shipped six
  months after the information is available to be
  labeled accordingly

77
Workplace Labels

• HazCom 2012 maintains the flexible approach to
  workplace labels in the current rule, i.e., the
  GHS label does not have to be on all workplace
  containers
• May Still use other label systems in Plant
• NFPA labels (problem with reverse hazard
  numbering)
• HMIS labels
• Workplace labels will have to be reviewed to make
  sure they still convey the correct hazards and
  other information when these new requirements are
  implemented

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The NFPA 704 System
79
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 1910.1200(f)(9)

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g) Safety Data Sheets

• HazCom 1994

• HazCom 2012

• Mandates 16-section SDS headings, order of
  information, and what information is to be
  provided under the headings
• Will not enforce sections 12-15 that require
  information outside OSHAs jurisdiction

• Specifies what information is required, but
  chemical manufacturer or importer can use
  whatever format or order of information they want

81
16 section - Safety Data Sheet

• 1.Identification of the substance or mixture and
  of the supplier
• 2.Hazards identification
• 3.Composition/information on ingredients
  Substance/Mixture
• 4.First aid measures
• 5.Firefighting measures
• 6.Accidental release measures
• 7.Handling and storage
• 8.Exposure controls/personal protection.
• 9.Physical and chemical properties
• 10.Stability and reactivity
• 11.Toxicological
• 12.Ecological information (non mandatory)
• 13.Disposal considerations (non mandatory)
• 14.Transport information (non mandatory)
• 15.Regulatory information (non mandatory)
• 16.Other information including information on
  preparation and revision of the SDS 

82
1910.1200(g)(2) And Appendix D

• Specifies the minimum information to be included
  in each of the 16 sections.
• Two revisions in this information are in the
  final rule
• ACGIH TLVs continue to be required on the SDS
• Information regarding carcinogenicity
  classifications by IARC and NTP also continue to
  be required
• Appendix C presents standardized hazard Signal
  word, Hazard statement(s),Pictogram(s), and
  Precautionary statement(s) to be included in
  section 2 of the SDS

83
Safety Data Sheets Key Changes
Safety Data Sheets Key Changes
Section 2 Hazard(s) Identification

• GHS Classification
• Pictogram(s)
• Signal Word
• Hazard Statement
• PrecautionaryStatement

84
SDS Sections

• From Appendix D

85
SDS Section 1

• Identification
• (a) Product identifier used on the label(b)
  Other means of identification(c) Recommended
  use of the chemical and restrictions on use(d)
  Name, address, and telephone number of the
  chemical manufacturer, importer, or other
  responsible party(e) Emergency phone number.

86
SDS Section 2

• Hazard(s) identification
• a) Classification of the chemical in accordance
  with paragraph (d) of 1910.1200(b) Signal
  word, hazard statement(s), symbol(s) and
  precautionary statement(s) in accordance with
  paragraph (f) of 1910.1200. (Hazard symbols may
  be provided as graphical reproductions in black
  and white or the name of the symbol, e.g., flame,
  skull and crossbones)(c) Describe any hazards
  not otherwise classified that have been
  identified during the classification process(d)
  Where an ingredient with unknown acute toxicity
  is used in a mixture at a concentration 1 and
  the mixture is not classified based on testing of
  the mixture as a whole, a statement that X of
  the mixture consists of ingredient(s) of unknown
  acute toxicity is required

87
SDS Section 3
Composition/ information on ingredients

• For Substances
• (a) Chemical name(b) Common name and
  synonyms(c) CAS number and other unique
  identifiers(d) Impurities and stabilizing
  additives which are themselves classified and
  which contribute to the classification of the
  substance.

88
SDS Section 3
Composition/ information on ingredients

• For MixturesIn addition to the information
  required for substances
• (a) The chemical name and concentration (exact
  percentage) or concentration ranges of all
  ingredients which are classified as health
  hazards in accordance with paragraph (d) of
  1910.1200 and(1) are present above their
  cut-off/concentration limits or (2) present a
  health risk below the cut-off/concentration
  limits. (b) The concentration (exact percentage)
  shall be specified unless a trade secret claim is
  made in accordance with paragraph (i) of
  1910.1200, when there is batch-to-batch
  variability in the production of a mixture, or
  for a group of substantially similar mixtures
  (See A.0.5.1.2) with similar chemical
  composition. In these cases, concentration ranges
  may be used.

89
SDS Section 3
Composition/ information on ingredients

• For All Chemicals Where a Trade Secret is Claimed
• Where a trade secret is claimed in accordance
  with paragraph (i) of 1910.1200, a statement
  that the specific chemical identity and/or exact
  percentage (concentration) of composition has
  been withheld as a trade secret is required.

90
SDS Section 4

• First-aid measures
• (a) Description of necessary measures, subdivided
  according to the different routes of exposure,
  i.e., inhalation, skin and eye contact, and
  ingestion(b) Most important symptoms/effects,
  acute and delayed.(c) Indication of immediate
  medical attention and special treatment needed,
  if necessary.

91
SDS Section 5

• Fire-fighting measures
• (a) Suitable (and unsuitable) extinguishing
  media.(b) Specific hazards arising from the
  chemical (e.g., nature of any hazardous
  combustion products).(c) Special protective
  equipment and precautions for fire-fighters.

92
SDS Section 6

• Accidental release measures
• (a) Personal precautions, protective equipment,
  and emergency procedures.(b) Methods and
  materials for containment and cleaning up.

93
SDS Section 7

• Handling and storage
• (a) Precautions for safe handling.(b) Conditions
  for safe storage, including any incompatibilities.

94
SDS Section 8

• Exposure controls/personal protection
• (a) OSHA permissible exposure limit (PEL),
  American Conference of Governmental Industrial
  Hygienists (ACGIH) Threshold Limit Value (TLV),
  and any other exposure limit used or recommended
  by the chemical manufacturer, importer, or
  employer preparing the safety data sheet, where
  available.(b) Appropriate engineering
  controls.(c) Individual protection measures,
  such as personal protective equipment.

95
SDS Section 9

• Physical and chemical properties
• (a) Appearance (physical state, color, etc.)(b)
  Odor(c) Odor threshold(d) pH(e) Melting
  point/freezing point(f) Initial boiling point
  and boiling range(g) Flash point(h)
  Evaporation rate(i) Flammability (solid,
  gas)(j) Upper/lower flammability or explosive
  limits(k) Vapor pressure(l) Vapor
  density(m) Relative density(n)
  Solubility(ies)(o) Partition coefficient
  n-octanol/water(p) Auto-ignition
  temperature(q) Decomposition temperature(r)
  Viscosity.

96
SDS Section 10

• Stability and reactivity
• (a) Reactivity(b) Chemical stability(c)
  Possibility of hazardous reactions(d)
  Conditions to avoid (e.g., static discharge,
  shock, or vibration)(e) Incompatible
  materials(f) Hazardous decomposition products.

97
SDS Section 11

• Toxicological information
• (a) Information on the likely routes of exposure
  (inhalation, ingestion, skin and eye
  contact)(b) Symptoms related to the physical,
  chemical and toxicological characteristics(c)
  Delayed and immediate effects and also chronic
  effects from short- and long-term exposure(d)
  Numerical measures of toxicity (such as acute
  toxicity estimates).(e) Whether the hazardous
  chemical is listed in the National Toxicology
  Program (NTP) Report on Carcinogens (latest
  edition) or has been found to be a potential
  carcinogen in the International Agency for
  Research on Cancer (IARC) Monographs (latest
  edition), or by OSHA.

98
SDS Section 12

• Ecological information (Non-mandatory)
• (a) Ecotoxicity (aquatic and terrestrial, where
  available)(b) Persistence and
  degradability(c) Bioaccumulative potential(d)
  Mobility in soil(e) Other adverse effects (such
  as hazardous to the ozone layer).

99
SDS Section 13

• Disposal considerations (Non-mandatory)
  Description of waste residues and information on
  their safe handling and methods of disposal,
  including the disposal of any contaminated
  packaging.

100
SDS Section 14

• Transport information (Non-mandatory)
• (a) UN number(b) UN proper shipping name(c)
  Transport hazard class(es)(d) Packing group, if
  applicable(e) Environmental hazards (e.g.,
  Marine pollutant (Yes/No))(f) Transport in bulk
  (according to Annex II of MARPOL 73/78 and the
  IBC Code)(g) Special precautions which a user
  needs to be aware of, or needs to comply with, in
  connection with transport or conveyance either
  within or outside their premises.

101
SDS Section 15

• Regulatory information (Non-mandatory) Safety,
  health and environmental regulations specific for
  the product in question.
• State/local laws
• OSHA expanded Health Standards

102
SDS Section 16

• Other information, including date of preparation
  or last revision
• The date of preparation of the SDS or the last
  change to it.

103
Safety Data Sheets (SDS)

• SDS in the workplace for each hazardous chemical
  which is used
• Readily accessible during each work shift to
  employees when they are in their work area(s)

104
h) Employee Information and Training

• HazCom 1994

• HazCom 2012

• Clarifies that the labels on shipped containers
  and workplace labels must be explained, as well
  as SDS format
• Workers will have to be trained on the new label
  and SDS formats before all the provisions of the
  rule are effective

• Requires employee information and training before
  a worker is exposed to the hazardous chemicals in
  the workplace, and whenever the hazard changes

105
Training

• Since the new label and SDS requirements will be
  phased in over several years, it is critical that
  employees understand the label and SDS formats,
  and the way information is conveyed
• Training on the system is thus the first
  compliance date for the rule workers are
  already starting to see GHS labels and SDSs on
  imported chemicals

106
Employee Training

• Location of program, list of chemical, and SDS
• Detection of chemical
• Hazards of chemical
• Protection measures
• Emergency procedures
• Labeling system used

• Trained initially and when new chemical
  introduced
• OSHA standard covered
• Operations in their work area where chemical is
  used
• Pictograms

107
i) Trade Secrets(AppendixE)

• HazCom 2012

• HazCom 1994

• Process remains the same
• Percentage of a substance in a mixture is also
  considered to be a type of trade secret subject
  to the provisions in the rule.

• Allows specific chemical identity to be protected
  when it is a legitimate trade secrete.
• Specifies conditions for protection, and for
  release when there is a safety and health need
  for the information

108
Implementation Dates
Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and SDS format. Employers
June 1, 2015December 1, 2015 Comply with all modified provisions of this final rule, exceptDistributors may ship products labeled by manufacturers under the old system until December 1, 2015. 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. Employers
Transition Period Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors and employers
This date coincides with the European Union
implementation date for classification of
mixtures.
109
Approach to Other Standards

• Many other OSHA standards contain criteria
  related to defining hazards, as well as other
  provisions that rely on those criteria
• OSHA undertook a comprehensive review of its
  rules to identify what needed to be changed
• OSHA has proposed modifications to all of those
  standards that it determined needed to be
  consistent with the GHS

110
Written Program

• Describes how the standard will be implemented in
  that facility  
• Contains a list of all chemicals

111
Program Requirements

• Written program
• List of all hazardous chemicals
• Addresses non-routine tasks
• Discusses other contractors responsibilities
• Available upon request to any employee or
  contractor

112
Develop Implementation Plans

• For Employers
• Initial employee training on the label elements
• Minimal training on new SDS format
• Continue to maintain the updated SDSs
• Review current hazard communication program and
  update as necessary
• For manufacturers
• Initial start-up costs associated with
  reclassification, producing new labels, safety
  data sheets, training.

113
Guidance Materials

• OSHA has and will continue to develop an array of
  guidance materials
• Initial Materials
• Quick Cards, Fact sheets, Small Entity Compliance
  guides
• Technical Materials
• Model Training materials Safety Data Preparation
  guidance Hazard Classification Guidance
• Web Applications
• http//www.osha.gov/dsg/hazcom/index.html

114
Impact on RCRA

• HazCom 2012 continues to exempt hazardous waste
  under 1910.1200(b)(6).
• Employers will need to train their employees on
  the new label and SDS requirements
• Use in the workplace
• Use in emergency response and contingency planning

115
Effect on Safety Professionals

• Become familiar with the new system
• Collect new SDSs as provided by suppliers and
  incorporate them into the existing MSDS system
  (or use commercial service)
• New GHS labels for shipped containers
• Employers can use other systems for workplace
  labeling
• Train employees on new labels and SDS

116
For More Information

• GHS text, UN papers and reports
• www.unece.org/trans/danger/danger.htm
• OSHA GHS information
• http//www.osha.gov/dsg/hazcom/index.html
• EPA GHS information
• www.epa.gov/oppfead1/international/globalharmon.h
  tm
• DOT GHS information
• www.hazmat.dot.gov/regs/intl/globharm.htm
• Canada GHS information
• http//www.hc-sc.gc.ca/ewh-semt/occup-travail/whm
  is-simdut/ghs-sgh/index_e.html

117
Reference Material

• Detailed Side-By-Side Review of the Regulatory
  Text Changes
• See OSHA Web Page at
• http//www.osha.gov/dsg/hazcom/side-by-side.html
• Federal Register (includes Preamble for
  reference)
• http//www.osha.gov/pls/oshaweb/owadisp.show_docum
  ent?p_tableFEDERAL_REGISTERp_id22607
• QA on the New Standard
• http//www.osha.gov/dsg/hazcom/hazcom-faq.html

118
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119
Questions?
120
Employee Training Program Framework Example

• Must be made site-specific and
• Health hazard slides added/modified to include
  specific examples of chemicals used by the
  individual employer.
• Labels
• SDSs
• The specific employers policies, procedures and
  responsible employees need to be identified and
  discussed (overall facilitys program details)

121
The GHS (HazComm 2012) Elements

• Classification Criteria
• Health
• Environment
• Physical
• Hazards not Elsewhere Classified
• Hazard Communication
• Labels
• Safety Data Sheets

122
Hazard Classification

• Chemical substances and mixtures are classified
  according to 18 physical and 11 health hazard
  classes
• Most hazard classes are sub-divided into hazard
  categories based on severity where, for example,
  1 is high and 5 is low.
• GHS allows for use of expert judgment and weight
  of evidence.
• Classification determines the signal words,
  pictograms, hazard and precautionary statements
  used to convey information on labels and safety
  data sheets (SDS).
• Adoption of GHS by OSHA does not affect DOT
  regulations as the classification and labeling of
  hazardous materials in transport have been
  harmonized for years.

123
HazComm2012 GHS Hazard Classes

• Physical
• Explosives
• Flammable gases
• Aerosols
• Oxidizing gases
• Gases under pressure
• Flammable liquids
• Flammable solids
• Self-reactive substances and mixtures
• Pyrophoric liquids
• Pyrophoric solids
• Self-heating substances and mixtures
• Substances and mixtures which in contact with
  water emit flammable gases
• Oxidizing liquids
• Oxidizing solids
• Organic peroxides
• Corrosive to metals
• Pyrophoric Gases
• Combustible Dust

• Health
• Acute toxicity
• Skin corrosion/irritation
• Serious eye damage/irritation
• Respiratory or skin sensitization
• Germ cell mutagenicity
• Carcinogenicity
• Reproductive toxicity
• Specific target organ toxicity (STOT SE) single
  exposure
• Specific target organ toxicity (STOT RE)
  repeated exposure
• Aspiration hazard
• Simple Asphyxiant
• Environmental
• Hazardous to the aquatic environment
• Hazardous to the ozone layer
• Hazards Not Elsewhere Classified

124
The GHS ClassificationHealth Environmental
Hazards

• Acute Toxicity
• Skin Corrosion/Irritation
• Serious Eye Damage/Eye Irritation
• Respiratory or Skin Sensitization
• Germ Cell Mutagenicity
• Carcinogenicity
• Reproductive Toxicity
• Target Organ Systemic Toxicity Single and
  Repeated Dose
• Simple Asphyxiant
• Hazardous to the Aquatic Environment

125
Health Hazards
Hazard Class Hazard Category Hazard Category Hazard Category Hazard Category
Acute Toxicity 1 2 3 4
Skin Corrosion/Irritation 1A 1B 1C 2
Serious Eye Damage/ Eye Irritation 1 2A 2B
Respiratory or Skin Sensitization 1
Germ Cell Mutagenicity 1A 1B 2
Carcinogenicity 1A 1B 2
Reproductive Toxicity 1A 1B 2 Lactation
STOT Single Exposure 1 2 3
STOT Repeated Exposure 1 2
Aspiration 1
Simple Asphyxiants Single Category Single Category
125
126
Physical Hazards

• Explosives
• Flammability gases, aerosols, liquids, solids
• Oxidizers liquid, solid, gases
• Self-Reactive
• Pyrophoric liquids, solids
• Self-Heating
• Organic Peroxides
• Corrosive to Metals
• Gases Under Pressure
• Water activated flammable gases
• Definitions, test methods and classification
  criteria are based on existing transport system
  (DOT Regulations)

127
Physical Hazards
128
System of Information and Communication

• Hazard Class
• Pictogram
• Signal Word
• Danger or Warning
• Hazard Statement
• i.e. combustible liquid,
• Precautionary Statement
• There are four types of precautionary statements
  presented
• "prevention,"
• "response,"
• "storage," and
• "disposal."

129
GHS Pictogram for Hazard Class
Explosives Self-reactive subst. Organic peroxide

Flammable substance Self-reactive substance
Pyrophoric and self- heating substance
Oxidizing substance Organic peroxides
Compressed gas
Sensitization (Respiratory) Mutagenicity
Carcinogenicity Reproductive toxicity Target
organ toxicity
Skin corr. Eye corr. Corrosive to metal
Acute toxicity
Acute toxicity Skin irrit. Eye irrit.
Sensitization (Dermal)
Environmental toxicity
130
Precedence of hazard
gt
gt
Skin/Eye irritation
Skin/Eye irritation
gt
gt
DANGER
WARNING
131
Transport Pictograms
Included in addition to GHS Pictograms and must
be maintained
132
Signal Word

• Danger or Warning
• Danger is more hazardous
• Used to emphasis hazard and to discriminate
  between hazard categories (level of hazard)
• e.g. Acute toxicity category 1 will require
  Danger, category 4 will require Warning

133
Hazard Category within a Hazard Class

• Hazard Categories are further subdivided into
  Hazard Classes
• Health Hazards
• Physical Hazards
• 1 is more hazardous than 4
• Opposite of NFPA Label System

134
The NFPA 704 System
135
Hazard Statements

• A single harmonised hazard statement for each
  hazard category within each hazard class

e.g. Flammable liquid - Category 1
Extremely flammable liquid and vapour
- Category 2 Highly flammable
liquid and vapour - Category 3
Flammable liquid and vapour -
Category 4 Combustible liquid
136
Hazard Statements (cont.)

• e.g. Oral Acute Toxicity
• Category 1
• Fatal if swallowed
• Category 2
• Fatal if swallowed
• Category 3
• Toxic if swallowed
• Category 4
• Harmful if swallowed
• Category 5
• Maybe harmful if swallowed

137
Allocation of Label Elements
Example Acute Toxicity (Oral)
138
Allocation of Label Elements (cont.)
Example Skin Corrosion/Irritation
139
Building Block Approach (Health)
Example Acute Toxicity (Oral)
Category 1 Category 2 Category 3 Category 4 Category 5
Danger Fatal if swallowed Danger Fatal if swallowed Danger Toxic if swallowed Warning Harmful if Swallowed No Symbol Warning May be harmful if swallowed
Not required under the TDG/MR Not required under the TDG/MR
140
Building Block Approach (Physical)
Example Explosives
Unstable/ Division 1.1 Division 1.2 Division 1.3 Division 1.4 Division 1.5 Division 1.6
Danger  Explosive mass explosion hazard   Danger Explosive severe projection hazard Danger  Explosive fire, blast or projection hazard 1.4  Warning  Fire or projection hazard 1.5  Warning  May explode in fire 1.6

141
Precautionary Statements

• There are four types of precautionary statements
  presented
• "prevention,"
• "response,"
• "storage," and
• "disposal."

142

• Epichlohydrin
• 1-Chloro-2,3-epoxypropane
• CAS No. 106-89-8
• UN No. 2023