Case Study for Globally Harmonized System ( GHS) Implementation in Industry

1. Case Study for Globally Harmonized System(GHS) Implementation in Industry Prepared for NC ASSE by Stephen Wrightenberry– Intern Cree EHS Presented by Erin Hite – EHS Program Manager, Cisco Systems ASSE Chapter meeting 12/13/12

2. Agenda • Overview of a sample plan to implement GHS in an industrial setting. • Objectives • Challenges • Plans and ideas • Will include tips and things to think about as you implement the program at your worksite. • Will not be a detailed review of the changes to the regulation (hopefully you already know the details!).

3. GHS Modifications to the Hazard Communication System • See handout for side by side comparison of 1994 and 2012 Hazcomm regulation changes • Sections with changes: • Purpose • Scope/Application • Definitions • Hazard Classification • Written Program • Labels • Safety Data Sheets • Employee Training • Trade Secrets These directly affect employees

4. Compliance Plan Timeline

5. Challenges for Implementation- Training • Timing for implementation – SDSs are already becoming available everywhere, need to train employees on how to read. • Training needs to cover: • Changes to HazCom, 16-section SDS, new label requirements, new classification system, any newly identified physical or health hazards on new SDSs to include in employee training • Include new label information in training • Since there will be new Manufacturer labels – if internal labels remain the same it will be confusing for employees. • New SDS will have classification numbers that are opposite of NFPA labels that are currently in use (1 is highest hazard rather than lowest hazard) • Classification system is more complicated. Individual employees may not be able to make label choices without EHS assistance. • Pictograms – new for employees – different from numbered hazard rating

6. Training Materials • Online Powerpoint class – required for all employees. • Updated website – with links to information and contacts for help • Posters – for work areas, gowning rooms, break rooms, bulletin boards • Badge Cards – for employees to carry • Newsletter – company wide prior to training. Sample Poster Materials from: GHS Compliance Kit KHA Online-MSDS Sample Badge Card

7. Train on 16-Section Safety Data Sheet Focus in employee Training will be on changes to these sections • Identification of the substance or mixture and of the supplier • Hazards identification • Information on ingredients (composition) substance/mixture • First Aid Measures • Firefighting Measures • Accidental Release Measures • Handling and Storage • Exposure controls/Personal protection • Physical and Chemical Properties • Stability and Reactivity • Toxicological • Ecological Information (Non-mandatory) • Disposal Considerations (Non-mandatory) • Transport Information (Non-mandatory) • Regulatory Information (Non-mandatory) • Other information including information on preparation and revision of the SDS

8. New Acetone SDS – Training Focus Classification and how to Interpret Chemical Identification Pictograms and what they mean Hazard Statements Handling and Prevention Response

9. Note: EHS should be aware of differences between GHS and other regulations - Example: Flammable and Combustible ranges:

10. Challenges for Implementation- Labels • LOTs and LOTs of labels! • Includes: squeeze bottles, equipment, tanks, hoods, buckets, beakers, jars and on and on! • Larger labels required – with inclusion of pictograms, hazard statements and other requirements. What to do with small containers? • Difficult to use preprinted labels for the multitude of chemicals (need all sizes, pictograms can’t be blank, who manages) • Manufacturer label pictograms need to be in color – determine if internal labels will follow this rule – requires specialized printers. • Finding printers made in the US to print updated labels (Printers available in the UK as of now; US is slowly transitioning printer labels over).

11. HazCom – Workplace Labeling • New HazCom regulation allows employers to use existing workplace-specific labeling systems as long as they provide the required information. • However, existing systems may not match what will now be on manufacturer labels and on the SDS. • Leads to confusion for employees so implementing consistent format is a good idea.

12. Example • Company is using NFPA/HMIS Labels on all non-manufacturer containers and equipment. • NFPA labels use number system to Rate the hazards. • 4 is high hazard, 1 is low hazard • GHS labels will have pictograms and hazard statement, SDS will classify using numbers • 1 is high hazard NFPA HMIS Sample GHS

13. Modifications to Labeling System • Internal labels should have the following: • Product Identifier • Pictogram • Signal Word • Hazard Statement(s) • Other: • Precautionary Statement(s) • Manufacturer contact info

14. HazCom Pictograms and Hazards

15. HazCom – Example of Manufacturer’s Label BIG!! Will need glasses to read if use all this information if used on secondary containers!

16. GHS labels – no standard format. • As you can see, the format may differ as long as the required information is present. • May need to have several options available for internal labels to accommodate container size and type of hazard.

17. Example preprinted label • Manu. labels require red outlines for pictograms. • Blank diamonds are not permitted on a label from manufacturer, but currently ok for site labels • Might change! • Black out pictograms that are not applicable? • Need to train employees how to complete label • What to do if updated SDS is not available?

18. Printing Options • Using in house printing will cut time in receiving labels and will also expedite the process, since labels can be designed, printed, and then posted. • Important to find a cost effective printer that can handle all necessary applications. • Would be great if integrated with existing MSDS system so labels would auto print based on specific MSDS information.

19. Challenges for Implementation- New SDSs • MSDS online system • Costs for uploading new SDSs, • Implementing label printing module (configure information from MSDS to label, train employees on how to use) • Manpower for requesting updated SDSs from all manufacturers • What to do when you don’t have an updated SDS? (product no longer made, manufacturer out of business, outside of US etc) • Who reviews for any newly identified physical or health hazards?

20. Classification Tables From: sigma-aldrich.com/safety-center.html This is a good reference for EHS professionals to check classifications and make label choices if MSDS is not available. http://www.labcluster.com/news4/30334_ghs_poster_eu.pdf

21. Classification Table- Codes

22. Questions?