GHS and The 2012 Hazcom Standard: A YEAR-PLUS IN: WHAT TRAINERS NEED TO THINK ABOUT NOW! August 22nd, 2013 Labelmaster Paul Burgess, DGSA Regulatory Specialist NKP 765 South at Jaite, Ohio, September 2010 Photo (c) Paul W. Burgess, all rights reserved The Hazcom Train is leaving the Station! Next Stop: Training for the GHS System! Objectives for this Presentation GHS Hazcom Summary General Rule/Outline Labeling and SDS Training Goals Timeline and Impact – What You Need to Think About NOW A Little History Early 70s – OSHA (Occupational Safety and Health Administration) Established 1983 – Hazard Communication Rule (29 CFR 1910.1200) Initial Promulgation 1992 – Rio De Janeiro UN Conference Sets Goal of a “Globally Harmonized System” of Hazard Communication in Transportation and Workplace by the Year 2000 What is GHS? GHS (Globally Harmonized System) Joint Global Framework of Guidelines Classifying and Communicating Chemical Hazards UN Created GHS, Updated as Conditions and Knowledge Change Current Iteration: 4th Revision. OSHA Hazcom Based on 3rd Revision What Isn’t GHS? “GHS” Itself is NOT: A Law A Regulation A Legal Standard An Industry Best Practice GHS is an Agreed Framework which Countries, Groups and other Interested or Affected Bodies can use to Create Harmonized Versions of the Above Benefits of GHS Full Implementation will Make Hazcom Understandable on a Global Basis Ease Burden of Hazard Communication for Global Trade/Remove “Technical Barrier” Some Countries Use Allow Workers to Change Jobs & Maintain Familiarity with the System Best of All-Increased Worker Safety! March 26th, 2012 – OSHA Acts The New Hazcomm Standard Promulgated as a Final Rule Effective Date: May 25th, 2012 The Standard is Now in Place in the US What Does it Do? Keeps Most Basic Elements of old Hazcom Standard in Place Changes the “How” Increases Worker Protection by Enhanced Requirements for Hazard Communication Labeling, Safety Data Sheets, & Strict Classification of Hazards Uses the GHS Rev. 3 as Baseline Implementation Dates Dec. 1, 2013 Employers must train employees on the new label elements and safety data sheet (SDS) format June 1, 2015 Chemical manufacturers, importers, distributors and employers must comply with all modified provisions Dec. 1, 2015 Distributors begin shipping containers labeled by the chemical manufacturer or importer with a HCS label June 1, 2016 Employers must update alternative workplace labeling and hazard communication programs as necessary and provide additional employee training for newly identified physical or health hazards Overview of: 29 CFR 1910.1200 (a)(1) The purpose of this section is to ensure that the hazards of all chemicals produced or imported are classified, and that information concerning the classified 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. What Has Changed? The prior version of the Hazcomm standard did not formally define “Classification” because that standard required “assessment of hazard” rather than “classification.” Legal Requirements for Classification 29 CFR 1910.1200 (d)(1) Chemical manufacturers and importers shall evaluate chemicals produced in their workplaces or imported by them to classify the chemicals in accordance with this section. For each chemical, the chemical manufacturer or importer shall determine the hazard classes, and where appropriate, the category of each class that apply to the chemical being classified. Employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer or importer for the chemical to satisfy this requirement. The Bottom Line: Old Standard: assumed hazard classification already existed, at least to a degree, and required assessment of already postulated risk. Hazcom 2012: requires an evaluation and assignment of the classification of the hazards themselves, along with assignment of risk. GHS Hazard Classifications Physical Hazards Explosives Flammable Gases, Aerosols, Liquids, Solids Oxidizers Self-Reactives Self-heaters Pyrophorics Organic Peroxides Corrosives Pressurized Gases Dangerous When Wet Health/Environmental Hazards Acute Toxicity Aspiration Skin Corrosion and Irritation Respiratory and/or Skin Sensitization Mutagenicity Carcinogenicity Reproductive Damage Organ Toxicity, Single and Multiple Doses Danger to Aquatic Environment Label Elements: Strictly Delineated by the regulation: Pictographic and Textual Information for Use on Hazard Warning Labels Deliberate Goal of the GHS Alignment Rule allows use of separate workplace-only systems provided that the GHS based system is still used on all shipped containers and employees are trained on both of the systems and any differences between them Labeling Under GHS-Based Systems GHS Labeling Largely Reflects Usage by USDOT/ICAO/IMO Transport World Internationally Recognized Pictograms Designed to Limit Need for Language Conversion from Country to Country Hazard Symbols and Classes Flame Flame Over Circle Exclamation Mark Flammables Self Reactives Pyrophorics Self-heating Emits Flammable Gas Organic Peroxides Oxidizers Irritant Dermal Sensitizer Acute Toxicity (harmful) Narcotic Effects Respiratory Tract Irritation Explosives Self Reactives Organic Peroxides Skull and Crossbones Corrosion Gas Cylinder Health Hazard Corrosives Gases Under Pressure Carcinogen Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity Aspiration Toxicity Exploding Bomb Acute Toxicity (severe) Label Elements, Applied Note: This is a fictitious example chemical The SDS (Safety Data Sheet) New Standard Converts Current Material Safety Data Sheets (MSDS) to Safety Data Sheets (SDS) Sections Harmonized with International Requirements Significantly More Information about Product, Use & Handling The SDS Format 1910.1200(g)(2)(i) Section 1, Identification 1910.1200(g)(2)(ii) Section 2, Hazard(s) identification 1910.1200(g)(2)(iii) Section 3, Composition/information on ingredients 1910.1200(g)(2)(iv) Section 4, First-aid measures 1910.1200(g)(2)(v) Section 5, Fire-fighting measures 1910.1200(g)(2)(vi) Section 6, Accidental release measures 1910.1200(g)(2)(vii) Section 7, Handling and storage 1910.1200(g)(2)(viii) Section 8, Exposure controls/personal protection 1910.1200(g)(2)(ix) Section 9, Physical and chemical properties 1910.1200(g)(2)(x) Section 10, Stability and reactivity 1910.1200(g)(2)(xi) Section 11, Toxicological information 1910.1200(g)(2)(xii) Section 12, Ecological information 1910.1200(g)(2)(xiii) Section 13, Disposal considerations 1910.1200(g)(2)(xiv) Section 14, Transport information 1910.1200(g)(2)(xv) Section 15, Regulatory information 1910.1200(g)(2)(xvi) Section 16, Other information, including date of preparation or last revision. Note 1 to paragraph (g)(2): To be consistent with the GHS, an SDS must also include the headings in paragraphs (g)(2)(xii) through (g)(2)(xv) in order. Note 2 to paragraph (g)(2): OSHA will not be enforcing information requirements in sections 12 through 15, as these areas are not under its jurisdiction! Training: The Initial Hurdle Coming Right Up: On December 1st, 2013 Employers MUST Train Employees to Understand and Use the New GHS-based System Even if the System has not yet been Placed in Service at the Place of Employment! Training Requirements 1910.1200(h) Employee information and training.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. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets Informing Your Staff 1910.1200(h)(2) Information. Employees shall be informed of: 1910.1200(h)(2)(i) The requirements of this section;1910.1200(h)(2)(ii) Any operations in their work area where hazardous chemicals are present; and,1910.1200(h)(2)(iii) The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and safety data sheets required by this section. Basic Training Summary Requirements due by 1 December: Label Elements SDS Format and Content Document this Training! 25 What You Need To Think About Now TRAIN YOUR EMPLOYEES December 1, 2013 Establishes that ALL Employees be Trained – that is only 3 months away! Most Employers Conduct “Right to Know” Training Yearly Now is Optimal Time to “Convert” This is a Large Change— Don’t Wait Until the Last Minute! (Which is almost here) How Can Labelmaster Help? THE LABELMASTER GHIS SYSTEM: Globally Harmonized Information System (GHIS) Training SDS Labeling Training Products LABELMASTER GHIS SYSTEM: Training Programs (Online & Book Formats) Instructor’s Resources on USB Student, Instructor & Implementation Manuals Training Kits and Reference Tools (Posters and Cards) Resources WWW.Labelmaster.com/GHS Senior GHS Liaison: Estuardo Sanchez: [email protected] GHS Regulatory Liaison: Paul Burgess, DGSA : [email protected] Extensive information and assistance available on Department of Labor/OSHA websites Information on the UN GHS Program Itself Can Be Found on the UN Website Many Local Governments also Offer Assistance The Wrap Up Questions? Clarifications? Want more? See our comprehensive Webinars. GHS Parts I through IV are Available on our Website: labelmaster.com/ghs Thank You So Much for Your Interest!