HCS and GHS

2. HCS and GHS Sheila Schulmeyer, CAS, LDO

3. GHS • On September 30, 2009 OSHA issued a proposed rule to aligned the OSHA Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) • On March 20, 2012 OSHA issued the Final Rule aligning the HCS to the GHS.

4. GHS • The benefits include enhanced worker comprehension resulting in appropriate handling and use of chemicals. The harmonized format of the safety data sheets will enable workers to access the information more efficiently • Also currently multiple labels and safety data sheets must often be developed by chemical manufacturers for the same product when shipped overseas. This creates a major compliance burden increasing costs

5. GHS • The benefit of the new system is that it provides a single set of criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets • The new HCS labels include signal words, pictograms, and hazard and precautionary statements • The Safety Data Sheets (SDS) will have a standardized format

6. GHS • The major changes to the HCS include: • Hazard Classification • Labels • Safety Data Sheets • Information and Training • The new HCS will affect nearly 40 million workers and 5 million workplaces and estimated to prevent 43 deaths and 585 injuries and illnesses annually

7. GHS • The DOT has already modified their requirements for classification and labeling to be consistent with UN transport requirements and the GHS

8. GHS Hazard Classification • The list of chemicals presenting a ‘Health’ hazard was deleted from the current HCS and the proposed HCS has identified a new listing • A ‘Health Hazard’ means a chemical which is classified as posing one of the following hazardous effects:

9. HCS Hazard Classification • Acute Toxicity (any route of exposure) • Skin Corrosion or Irritation • Serious Eye Damage or Eye Irritation • Respiratory or Skin Sensitization • Germ Cell Mutagenicity • Carcinogenicity • Reproductive Toxicity • Specific Target Organ Toxicity (single or repeated exposure) • Aspiration Hazard

10. HCS Hazard Classification • The list of chemicals presenting a ‘Physical’ hazard was deleted from the current HCS and the proposed HCS has identified a new listing • A ‘Physical Hazard’ means a chemical that is classified as posing one of the following hazardous effects:

11. HCS Hazard Classification • Explosive • Flammable (gases, aerosols, liquids, or solids) • Oxidizer (liquid, solid, or gas) • Self-Reactive • Pyrophoric (liquid or solid) • Self-Heating • Organic Peroxide • Corrosive To Metal • Gas Under Pressure • Contact With Water Emits Flammable Gas

12. HCS Hazard Classification • The HCS does not address environmental hazards and OSHA does not have jurisdiction over that. There are environmental hazard classifications: • Hazardous to the Aquatic Environment • Acute Aquatic Toxicity • Chronic Aquatic Toxicity • Bioaccumulation Potential • Rapid Degradability

13. OSHA Hazard Classification • In OSHA’s HCS standard there is a hazard category called ‘Hazards Not Otherwise Unclassified’ (HNOC) which is not in the UN GHS system… • ...means an adverse physical or health effect identified through evaluation of scientific evidence during the classification process that does not meet the specific criteria for the physical and health hazard classes addressed in this section

14. OSHA Hazard Classification • Hazards Not Otherwise Classified (HNOC) will not be required to be listed on the label but will be disclosed in Section 2 (Hazards Identification) of the SDS • Combustible Dusts, Simple Asphyxiants, and Pyrophoric Gasses were removed from the HNOC and will be treated individually as hazardous chemicals • Will be addressed on labels and SDS with signal words and hazard statements

15. HCS Labels • Three standardized HCS label elements: • Symbols (Hazard Pictograms) that convey health, physical, and environmental hazard information assigned to a GHS hazard class and category • Signal Words “Danger” or “Warning” used to emphasize hazards and relative level of severity of the hazard and assigned to a GHS hazard class and category • Hazard Statements which are standard phrases assigned to a hazard class and category that describe the nature of the hazard

16. HCS Labels

17. HCS Pictograms Red border GHS ------ Black border Transport

18. HCS Pictograms Hazard Classes may have ‘Categories’

19. Safety Data Sheets (SDS) • The OSHA ‘Material Safety Data Sheet’ (MSDS) is now called a ‘Safety Data Sheet’ (SDS) • The MSDS had 8 non-mandatory sections • The SDS has 12 mandatory and 4 non-mandatory sections and is essentially the ANSI Z400.1-2004 format • Sections 12-15 are not mandatory and cover Ecological, Disposal, Transport, and Regulatory information

20. Safety Data Sheets (SDS) Sections • 1. Identification • 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 • 9. Physical and chemical properties • 10. Stability and reactivity • 11. Toxicological information • 12. Ecological information • 13. Disposal considerations • 14. Transport information • 15. Regulatory information • 16. Other information, including date of preparation/revision Not required by OSHA

21. Safety Data Sheets (SDS) What a New ‘SDS’ May Look Like The old Non-Mandatory ‘MSDS’

22. HCS Information and Training Dates • December 1, 2013 workers must be trained on the new labels and Safety Data Sheets • June 1, 2015 chemical manufacturers, importers, distributors, and employers etc. must be in compliance with all modified provisions of the HCS • June 1, 2016 employers must update alternative workplace labeling and hazard communication programs as necessary, and provide additional worker training for new identified physical and health hazards

23. HCS Information and Training Dates • Distributers may ship products labeled by manufacturers under the old system until December 1, 2015 • Six months to revise and use new labels when significant information about a chemical is discovered • SDS will still be required to have ACGIH TLVs and OSHA PELs listed

24. HCS Appendices • Appendix A: Health Hazard Criteria • Appendix B: Physical Hazard Criteria • Appendix C: Allocation of Label Elements • Appendix D: Safety Data Sheets • Appendix E: Definition of ‘Trade Secret’ • Appendix F: Guidance for Hazard Classification Regarding Carcinogenicity

25. GHS Changes in the Future • The HCS will be updated as needed to reflect new technology and scientific developments, or provide explanatory text. Changes to the HCS is anticipated through: • Technical Updates for minor terminology changes • Direct Final Rules for text clarification • Notice and Comment Rulemaking for more substantive or controversial updates such as additional or changes in health or safety hazard classes or categories

26. Resources • The GHS is going to be found in the ‘GHS Purple Book’ • You can purchase from the UN bookstore if you are looking for information related to the GHS

27. Resources • On the OSHA website under ‘Safety and Health Topics’ there is a Hazard Communication webpage with many resources and documents such as the Federal Register, ‘Old’ vs ‘New’ standard comparison… http://www.osha.gov/dsg/hazcom/index.html

28. Resources

29. Resources • OSHA published ‘A Guide to The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) • It can be downloaded from the OSHA website

30. Where is OSHA Located? Lubbock District Office 1205 Texas Ave., Room 806 Lubbock, Texas 79401 806-472-7681 Sheila Schulmeyer, CAS schulmeyer.sheila@dol.gov Ext at above number is 227

31. Disclaimer • This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics [or hazards], it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at www.osha.gov.