Hazard Communication and the Globally Harmonized System (GHS) Training

1. Hazard Communication and the Globally Harmonized System (GHS) Training Presented by PLANET* *The Professional Landcare Network (PLANET) provides this PowerPoint presentation as a service to its members in furtherance of PLANET’s mission. PLANET is not responsible for, and expressly disclaims all liability for, damages of any kind arising out of use, reference to, or reliance on any information contained within the presentation. Please refer to OSHA requirements to provide this training to your employees. The following information is a general review of the subject matter.  Please consult with a subject matter expert for compliance review and advice.

2. Introduction This presentation contains information about employer responsibilities with regards to the revised Hazardous Communications Standards (also known as the Globally Harmonized System (GHS) of Classification & Labeling of Chemicals) and for use in training employees on the new label elements and safety data sheet format associated with GHS.

3. Table of Content

4. Why did OSHA align theHCS with GHS? • To provide a common, coherent approach to classifying and communicating chemical hazards. This approach includes: • Harmonized (standardized) definitions of hazards • Specific criteria for labels • Harmonized (standardized) format for safety data sheets

5. Benefits of Adopting the GHS • Increase the quality and consistency of information provided to workers, employers and chemical users. • Reduce confusion/Increase comprehension of hazards. • Improve downstream risk management. • Facilitate training. • Help address literacy problems. • Other benefits include facilitation of international trade in chemicals

6. Note: • OSHA is moving forward to change the MSDS and all chemical labels to comply with GHS; however, the EPA will not require any changes to pesticide labels. • This may cause confusion since the signal word on the OSHA-regulated SDS will not match the signal word on the EPA-regulated pesticide label. • “Danger” and “Warning” are the only two signal words that will appear on the revised HCS; Pesticide labels will continue to use the current signal words “Caution,” “Warning,” and “Danger.”

7. Purpose OSHA requires that by Dec. 1, 2013, each person in your company who deals with chemicals must be verifiably trained on: • Label elements of non-pesticide chemicals • The new SDS format applicable to both pesticides and non-pesticides OSHA requires this to ensure that the hazards of all chemicals, produced or imported, are classified and that information about their hazards is given to employers and their employees.

8. How Hazard Communication Works

9. Employer Responsibilities - Labels • Maintain labels on the containers, including , but not limited to, tanks, totes and drums, so they continue to be legible and the pertinent information is not defaced (i.e., fade, get washed off) or removed in any way. • Re-label items if the labels are removed or defaced. • Labels must be legible, in English, and prominently displayed. Other languages may be displayed in addition to English. • General OSHA requirements for workplace labeling have not changed. • Employers have option to create their own workplace labels. • Employer with workplace system of labeling that meets the requirements of HazCom 1994 may continue to use this system as long as it provides employees with the information on all of the health and physical hazards of the hazardous chemical.

10. Employer Responsibilities - Labels • If an employer chooses to use the GHS pictograms, these pictograms may have a black border, rather than a red border (manufacturers, importers, or distributors shipping or transporting hazardous chemicals must to use pictograms with red border with a black hazard symbol on a white background). • Employer may use additional instructional symbols, not included in OSHA’s HCS pictograms (e.g., a person wearing goggles or an environmental or PPE pictogram) on workplace labels. • Note: If an employer transfers hazardous chemicals from a labeled container to a portable container that is only intended for immediate use by the employee who performs the transfer, no labels are required for the portable container.

11. Employer Responsibilities - SDS • Designatepersonto obtainSDS • Maintain SDS • (e.g., Notebooks,electronic,back-upsystem, access) • Know proceduresto followto obtain SDS • Follow proceduresfor updatingSDS • Chemicalmanufacturersandimporters • Have SDS readily accessible and available upon request • (e.g., Main offices, work areas, mobile locations)

12. Checklistfor Employer Compliance • Obtainacopyof therule • Readandunderstandtherequirements • Assignresponsibilityfortasks • Prepareaninventoryof chemicals • Ensurecontainersarelabeled • ObtainSDSfor eachchemical • Preparewrittenprogram (when required under new program you should update your old program)

13. Checklistfor Employer Compliance • Make SDS available to workers • Conduct training of workers • Establish procedures to maintain current program • Establish procedures to evaluate effectiveness

14. Final Rule • The final rule was published in the Federal Register on March 26, 2012 and became effective on May 25, 2012. The rule can be found at • https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=22607

15. Phase-in period for the revised Hazard Communication Standard *This date coincides with the EU implementation date for classification of mixtures

16. Training Outline • Lesson 1: Label elements • What is HCS definition of a label • Type of information employee would expect to see on the new labels. • How employee might use that information • Lesson 2: Safety Data Sheet Format • Standardized 16-section format • Type of information found in the various sections

17. Lesson 1: Label elements HCS definition of a label: • An appropriate group of written, printed or graphic informational elements concerning a hazardous chemical that are affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging.

18. Lesson 1: Label elements Labels for a hazardous chemical must contain: • Name, Address, and Telephone Number • Product Identifier • Signal Word • Hazard Statement(s) • Precautionary Statement(s) • Pictogram(s)

19. SampleLabel

20. SampleLabel

21. SampleLabel

22. Lesson 1: Label elements (instructor slide) Labels for a hazardous chemical must contain: Name, Address, and Telephone Numberof the chemical manufacturer, importer or other responsible party. Product Identifier: the chemical name, code number or batch number. (the manufacturer, importer or distributor can decide the appropriate product identifier, but the same product identifier must be both on the label and in section 1 of the SDS. Signal Word to indicate the relative level of severity of the hazard and alert the reader to a potential hazard. • “Danger” and “Warning” are the only two words used as signal words; there will only be one signal word on the label, no matter how many hazards a chemical may have.

23. Lesson 1: Label elements (instructor slide – cont.) Labels for a hazardous chemical must contain: Hazard Statement(s) todescribe the nature of the hazard(s) of a chemical, including where appropriate the degree of hazard. • For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.”

24. Lesson 1: Label elements (instructor slide – cont.) Labels for a hazardous chemical must contain: Precautionary Statement(s)* describe recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to or improper storage or handling of the hazardous chemical. There are four types of precautionary statements: 1. Prevention (to minimize exposure) 2. Response (in case of accidental spillage or exposure emergency response and first-aid) 3. Storage 4. Disposal

25. Lesson 1: Label elements (instructor slide – cont.) Labels for a hazardous chemical must contain: Precautionary Statement(s)* – example: A chemical presenting a specific target organ toxicity would include the following on the label: “Do not breathe dust/fume/gas/mist/vapors/spray. Get medical advice/attention if you feel unwell. Dispose of contents/container in accordance with local/regional/national and international regulations.” *See OSHA Brief on Hazard Communication Standard: Labels and Pictograms for more details.

26. Lesson 1: Label elements (instructor slide – cont.) Examples of Precautionary Statements:

27. Lesson 1: Label elements (instructor slide – cont.) Labels for a hazardous chemical must contain: Pictogram(s) graphic symbols used to communicate specific information about the hazards of a chemical. indicate the relative level of severity of the hazard and alert the reader to a potential hazard. • “Danger” and “Warning” are the only two words used as signal words; there will only be one signal word on the label, no matter how many hazards a chemical may have.

28. Lesson 1: HCS Pictograms and Hazards OSHA has designated eight pictograms under this standard for application to a hazard category (see following slide). OSHA’s required pictograms must Be in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame sufficiently wide enough to be clearly visible. • A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label.

29. Lesson 1: HCS Pictograms and Hazards

30. Lesson1: How Employee might use the labels in the workplace • To ensure proper storage of hazardous chemicals. • To quickly locate information on first aid when needed by employees or emergency personnel.

31. Lesson 1: How elements on label work together • Some chemicals may have multiple hazards, different pictograms are used to identify the various hazards. You should expect to see the appropriate pictogram for the corresponding hazard class. • When there are similar precautionary statements, the one providing the most protective information will be included on the label.

32. Lesson 2: Safety Data Sheet Format • HCS requires chemical manufacturers, distributors, or importers to provide Safety Data Sheets (SDS, formerly known as Material Safety Data Sheets (MDS)) to communicate the dangers of hazardous chemical products. • As of June 1, 2015, the HCS will require new SDS to be in a uniform format and include the following 1-16 section numbers, with the headings, and associated information:

33. Lesson 2: SDSFormat Sections • Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use. • Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements. • Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims. • Section 4, First-aid measures includes important symptoms/effects, acute, delayed; required treatment.

34. Lesson 2: SDSFormat Sections • Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire. • Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup. • Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities. • Section 8, Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).

35. Lesson 2: SDSFormat Sections • Section 9, Physical and chemical properties lists the chemical’s characteristics. • Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions. • Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity. • Section 12, Ecological information* • Section 13, Disposal considerations* • Section 14, Transport information*

36. Lesson 2: SDSFormat Sections • Section 15, Regulatory Information,* this section documents the chemical’s classification under federal regulations such as the Toxic Substances Control Act, the Clean Water Act and the Superfund Amendments and Reauthorization Act among others. Special Information for pesticides included in this section. EPA has instructed manufactures/suppliers to insert the required FIFRA label hazard information in this section. If the pesticide label signal word is different from the signal word on the SDS, (new standard does not use “Caution”) this is where it is explained. • Section 16, Other information, includes the date of preparation or last revision. *Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)).

37. Lesson 1 & 2: Wrap-up • Summarize important points. • Allow time for questions.

38. Additional Training Resources • OSHA Hazard Communication website: https://www.osha.gov/dsg/hazcom/index.html • Federal Register Hazard Communication Rule: https://www.osha.gov/FedReg_osha_pdf/FED20120326.pdf • Hazard Communication Safety Data Sheets Quick Card: https://www.osha.gov/Publications/HazComm_QuickCard_SafetyData.html

39. Additional Training Resources • Hazard Communication Standard QuickCards https://www.osha.gov/dsg/hazcom/ghsquickcards.html

40. Assessment and Evaluation • GHS stands for: a. Globally Harmonized System b. Good Health Safety c. Global Health Strategies 2. The GHS system provides for: a. Improved understanding and communication b. More OSHA citations and penalties • A chemical in hazard category 4 represents which category of hazard? a. Most hazardous category in that hazard class b. Least hazardous category in that hazard class • The words “danger” or “warning” are examples of: a. Signal words c. Pictograms b. Hazard statements d. Precautionary statements

41. Assessment and Evaluation 5. A workplace label must always contain the name, address, and telephone number of the chemical’s manufacturer or supplier. a. True b. False 6. OSHA will strictly enforce Environmental requirements. a. True b. False • A chemical in a secondary container that has not been labeled with a workplace label will still be in compliance, provided the worker who labeled it will be the same worker to use the chemical the following workday. a. True b. False • Safety Data Sheets must follow a uniform format consisting of 18 sections of information. a. True b. False

42. Assessment and Evaluation • Businesses that have employees who travel for work at off-site locations are required to keep Safety Data Sheets in every vehicle. a. True b. False 10. Under the requirements of the GHS system, manufacturers will transmit information about hazardous chemicals through: a. Material Safety Data Sheets b. Safety Data Sheets • The responsibility for classifying chemicals is a requirement for: a. Assigned by the manufacturer, producer, or importer b. Assigned by an employer, if desired c. both

43. Assessment and Evaluation • 1. Answer a: Globally Harmonized System • 2. Answer a: Improved understanding and communication • 3. Answer b: Least hazardous category in that hazard class • 4. Answer a: Signal words • 5. Answer b: False • 6. Answer b: False • 7. Answer b: False • 8. Answer b: False (16)

44. Assessment and Evaluation • 9. Answer b: False • 10. Answer b: Safety Data Sheets • 11. Answer a: Assigned by the manufacturer, producer, or importer