Hazard Communication and the Globally Harmonized

Report
Hazard Communication and the
Globally Harmonized System (GHS)
Goals for this session…
• Address common hazard
communication violations…
• Understand major elements of
hazard communication & global
harmonization
• Answer your questions
Have you recently checked all the
work and storage areas to ensure
you have a comprehensive list of
all of the chemicals at your site,
including products brought to your
site by contractors?
Does your hazard communication
program identify the method you will
use to inform employees of the
hazards of non-routine tasks and
procedures for sharing information
with employees other than your
own?
Have you checked this month to
ensure all secondary containers are
labeled with an appropriate hazard
warning?
Do you have the ability to send a
MSDS for a product [nox-rust (19)] to
the hospital with an injured employee?
Do you have evidence your
employees have been trained
on the health hazards of all of
the chemicals they can smell
at work?
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
Products and chemicals not covered
• Hazardous waste covered RCRA (EPA).
• Hazardous substances when it is the focus of remedial or removal action
conducted under CERCLA (EPA)
• Tobacco or tobacco products.
• Wood or wood products
» treated wood and wood that is cut generating dust are not exempt
• Articles - not a fluid or particle in its end use that does not release hazardous
chemicals and does not pose a health risk
• Food or alcohol sold in retail for personal consumption.
• Any drug defined by the Federal Food, Drug, and Cosmetic Act.
• Cosmetics for personal use.
• Any consumer product covered by the CPSC.
• Nuisance particulates that do not pose a physical or health hazard.
• Ionizing and nonionizing radiation.
• Biological hazards
Consumer Products
• defined as such under the CP Safety Act
• used as intended by the manufacturer
• used with the same frequency and duration of a
typical consumer.
• Windex – Isopropanol & Ethyleneglycol Monohexylether
» Flash point - 130°F
» sprayed onto glass for cleaning
» Is the frequency and duration of exposure is greater than
a normal consumer?
No change to basic hazard
communication program
• Management responsibility for program
• Develop list of hazardous chemicals
• Label hazardous chemical containers
• Manage Safety Data Sheets
• Procedures for training exposed employees
• Address the hazards of non-routine tasks
• Procedures for Multi-employer workplaces
Currently chemicals labeled with…
• Chemical identity
• Appropriate hazard warnings
• Name and address of the responsible party
The one, one, one rule.
• When a hazardous chemical is transferred into
one container for the immediate use (one shift)
by one employee, then the container does not
have to be labeled.
• Any residual in the container must be
immediately recycled or treated as waste.
Safety Data Sheets
• If SDS has been
received for a
hazardous chemical,
employer must
contact the supplier,
manufacturer, or
importer to obtain one
and maintain a record
of the contact
Safety Data Sheet
• Accessible during each work shift.
• Must be in English
• Electronic access and alternatives to
paper are permitted as long as
barriers to access are not created.
Hazard Communication
Training
• At the time of
initial assignment
• Whenever a new
hazard is
introduced in the
work area
Employee information
• The requirements of the standard.
• Operations in their work area where
hazardous chemicals are present.
• The location and availability of the
written program, hazardous chemical list,
and material safety data sheets.
Employee training
• Methods and observations used to detect a release of a
hazardous chemical (monitoring, odor, visual appearance)
• The physical and health hazards of chemicals in the work
area.
• The measures employees can take to protect themselves
(specific procedures, work practices, emergency procedures,
and ppe)
• The details of the hazard communication program (labeling,
SDS’s, and how to obtain and use the information.
Standard for a Globally Harmonized
System of Classification and
Labeling of Chemicals
Development of Final Rule
• NPRM Published in the Federal Register
on September 30, 2009 (74 FR 5028050549).
• The final rule was published in the
Federal Register on March 26, 2012 and
became effective on May 25, 2012.
Why GHS?
• Uniform information to communicate
chemical hazards for international trade
• 50,000 chronic illnesses in 1992 from
occupational exposure to chemicals
• Could prevent 43 fatalities annually
In hazard communication 2012…
• Hazard classification: Provides specific criteria for
classification of health and physical hazards
• Labels: Chemical manufacturers and importers will be
required to provide a label that includes a harmonized signal
words, pictogram, and hazard statement for each hazard class
and category.
• Safety Data Sheets: Will now have a specified 16-section
format.
• Information and training: The GHS requires workers be
trained to understand the new labels and safety data sheets.
Organization of the Final Rule
a) Purpose
g) Safety Data Sheets
b) Scope and Application h) Employee Information
and Training
c) Definitions
d) Hazard Classification i) Trade Secrets
j) Effective Dates
e) Written Hazard
Communication
Program
f) Labels and Other
Forms
of Warning
Appendices A–F
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 Hazard Classifications
re: Carcinogenicity (Non-Mandatory) (NEW)
Important Dates
Effective
Completion Date
Requirement(s)
Who
Train employees on the new label elements and SDS Employers
December 1, 2013 format.
Comply with all modified provisions of this final rule, Chemical manufacturers,
June 1, 2015
except distributor extension
importers, distributors and
employers
Distributors may ship products labeled by manufacturers under the old system
December 1, 2015 until December 1, 2015.
Update alternative workplace labeling and hazard
Employers
June 1, 2016
communication program as necessary, and provide
additional employee training for newly identified
physical or health hazards.
Comply with either 29 CFR 1910.1200 (this final
All chemical
Transition Period standard), or the current standard, or both.
manufacturers, importers,
distributors and employers
Hazard Classification
Chemical manufacturers and importers
must classify each chemical they
produce or import:
Determine the appropriate hazard classes and
associated hazard categories
Base this on an evaluation of the full range of
available data/evidence on the chemical
Use Appendix A for health hazard criteria and
Appendix B for physical hazard criteria
10 health hazard categories and
16 physical hazard categories.
Health Hazard Classifications
Hazard Class
Acute Toxicity
Hazard Category
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
STOT - Specific Target Organ
Toxicity
Single Exposure
1
2
STOT –
Repeated Exposure
1
2
Aspiration
1
Simple Asphyxiants
Single Category
3
Lactation
Physical hazard classification
Hazard Class
Explosives
Flammable Gases
Flammable Aerosols
Oxidizing Gases
Gases under Pressure
Hazard Category
Unstable
Explosives
Div 1.1
1
1
1
1
2
2
Div 1.2
Div 1.3
Div 1.4
Div 1.5
Div 1.6
3
Type C
4
Type D
Type E
Type F
Type G
Type D
Type E
Type F
Type G
Compressed Gases
Liquefied Gases
Refrigerated Liquefied Gases
Dissolved Gases
Flammable Liquids
Self-Reactive Chemicals
Pyrophoric Liquids
Pyrophoric Solid
Pyrophoric Gases
Self-heating Chemicals
Chemicals, which in
contact with water, emit
flammable gases
Oxidizing Liquids
Oxidizing Solids
Organic Peroxides
Corrosive to Metals
Combustible Dusts
1
Type A
1
1
Single
category
1
1
2
Type B
1
1
Type A
1
Single
Category
2
2
Type B
2
2
3
3
3
Type C
Training
• Train employees on the new label elements
and SDS format by December 1 , 2013.
• Provide additional training for any newly
identified physical or health hazards by June
1, 2016.
Labels
• Pictograms
• signal words
• hazard and
precautionar
y statements
• the product
identifier
• supplier
identification.
Other hazards which do not result in
classification
• Combustible dusts
• OSHA includes dusts under its definition for
hazardous chemicals, requiring that employers
account for them on safety data sheets and in
worker training.
• signal word “warning”
• hazard statement “may form combustible dust
concentrations in air”
No more combustible liquids?
• Flammable liquids category 1, 2, 3 & 4
» No longer use 100 F – 23 C or 95 F
16-Section Safety Data Sheet
1. Identification of the substance
or mixture and of the supplier
2. Hazard(s) identification
3. Composition/information on
ingredients
4. First aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal
protection
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
9. Physical and chemical properties
revision of the SDS
Appendix D
• Specifies the minimum information to be
included in each of the 16 sections.
• Two revisions 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.
To do list…
• For Employers
» Review current hazard communication program
and update yours to meet 2012 requirements
» Training on the label elements
» Training on new SDS format
» Start obtaining the updated SDSs
• For Manufacturers
» Start classification of products, develop new
labels, update safety data sheets, help save lives
or prevent disease.
A Guide to The Globally Harmonized System of
Classification and Labeling of Chemicals (GHS)
• http://www.osha.gov/dsg/hazcom/ghs.html

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