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HOW TO MANAGE THE NEW HAZCOM STANDARD

HOW TO MANAGE THE NEW HAZCOM STANDARD. 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).

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HOW TO MANAGE THE NEW HAZCOM STANDARD

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  1. HOW TO MANAGE THE NEW HAZCOM STANDARD

  2. 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 same—to 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.”

  3. 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.

  4. 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

  5. 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).

  6. 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.)

  7. 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.

  8. 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

  9. 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.

  10. 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.

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

  12. Effective Dates for Compliance

  13. GHS Authoring Costs: OSHA vs. Industry Analysis • OSHA’s 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 • Industry’s 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: >400K MSDS / 9.2 hours per doc / >$600 per MSDS = estimated total cost $250M

  14. 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

  15. 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_rev03/03files_e.html • OSHA’s Notice of Proposed Rulemaking on the GHS is available at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_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.html#documents - go to 'Products and Resources'. • or SCHC site: http://www.schc.org/issues.php?start_from=5&ucat=&archive=&subaction=&id=&cat=9 - 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.html

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