Globally Harmonized System/ Hazard Communication (Right-To-Know) CFR 1910.1200

1. Globally Harmonized System/Hazard Communication (Right-To-Know)CFR 1910.1200

2. Why Did OSHA Align the HCS with GHS? • A common coherent approach to classifying and communicating chemical hazards. • Harmonized definitions of hazards • Specific criteria for labels • Harmonized format for safety data sheets

3. Benefits of Adopting the GHS • Increase the quality and consistency of information provided to the workers, employers and chemical users. • Reduce confusion/increase comprehension of hazards • Improve downstream risk management • Facilitate training • Help address literacy problems

4. The Old System

5. The New System

6. A Brief History of GHS: It is not a new idea • It was first discussed in 1983 • It was hoped that a global harmonized system (GHS) would be in place by 2000 • However it was not until 2005 that OSHA finally agreed to modify the HCS (Hazard Communication Standard) to add the adoption of GHS.  • In 2009 OSHA asked for input from any and all interested parties  • August of 2011 OSHA postponed release of final documents  • Sept of 2011 OSHA issued final recommendations and guidelines for implementation, with a three year window for companies to implement the GHS in their HCS programs  • 2012 begins the three year timeframe to begin implementation of GHS  • 2015 the date by which all chemical companies should have switched over product labeling and labeling on items transported to GHS 

7. Scenario You are unloading three chemical containers from three different manufacturers. The containers all give various warnings regarding the chemical inside: #1 “flammable” #2 “very flammable” #3 “highly flammable” Which chemical container is most dangerous?

8. Answer They are all the same chemical, and thus one container’s contents are no more dangerous than the others despite what confusion the labels may create. This is the reason for transitioning to GHS.

9. Effective Dates • 12/1/13: All employees must be trained on new label elements and SDS format • 6/1/15: Manufacturers and distributors must comply with all modified provisions except that distributors have until 12/1/15 to provide revised labels for all products shipped. • 6/1/16: OSHA enforcement starts: Employers must update all labels and Haz Com program, provide additional training for workers on newly identified physical or health hazards Note: During transition period, employers can comply with old or new standard as far as labels and SDSs.

10. Employee Training • Provide information and train prior to initial assignment to work with a hazardous chemical • Do initially, periodically, and whenever the hazard changes • Must occur within 30 days of employment for new employees, full or part time • Must be documented with detailed records of training maintained by the entity and available for review by supervisor, Safety Officer or training staff

11. Employee Trainingcontinued Training shall include: • Explanation of Hazard Communication Program • Explanation of SDSs and how to access an SDS • Review of chemicals used on site • Review of work area locations using hazardous products • Identification of hazards associated with the use of chemicals • Review of protective measures required for specific hazards • Explanation of the labeling system

12. Notable Changes to Standard • Using a “specification” approach rather than a “performance-oriented” approach • “Hazard classification” rather than “hazard determination” • Labels are more defined • “Safety data sheet” (rather than material safety data sheet) uses a 16 section format

13. OSHA Standard(Also known as “Right to Know”) • 5 Steps to Compliance • Develop a written Hazard Communication plan. • Inventory all hazardous chemicals. • Establish and maintain a complete library of Safety Data Sheets (SDS). • Label all containers, pipes and tanks. • Provide equipment and train your workforce.

14. Contents of the OSHA Standard(Exemption) The HCS does not apply to consumer products when used in the workplace in the same manner and with the same duration and frequency that a normal household consumer would use them at home.

15. Labeling According to GHS Labels must be affixed to, printed on or attached to each chemical container in the workplace. Information required on a GHS label: • Product identifier • Supplier identification • Signal word • Hazard statement • Pictogram • Precautionary statement Optional: Supplemental info

16. Labeling According to GHS - Workplace

17. Labeling According to GHS - Transport Shipping Container Label (55 gallon/200 liter drum) Effective June 1, 2015 all shipping labels will be required to have all GHS label elements Pictograms within DOT label DOT Shipping Flammable liquids, toxic, n.o.s. (contains XYZ) UN 1992

18. Labeling of Secondary Containers If hazardous chemicals are transferred into unmarked containers: • label container with the required information (GHS label elements) • unless the container is intended for immediate use by employee who performed the transfer (use portable container labeling guidelines)

19. Labeling of Portable Containers Employer is NOT required to label portable containers which are intended only for the immediate use of the employee who performs the transfer…

20. Updating Labels Labels and SDS’s should be updated within 6 months when new and significant information is available for a chemical. “New and significant information” means any information that changes GHS classification and leads to a change in the information to be provided in the label or in the SDS.

21. Product Identifier Definition: Unique name or number used

22. Supplier Identification Definition: name, address and telephone number of the manufacturer or supplier of the substance/mixture

23. Signal Words Definition: word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label “Danger” (for more severe hazard categories) “Warning” (for less severe hazard categories) *Only one of these words will be present on a label.

24. Hazard Statement Definition: phrase assigned that describes the nature of the chemical hazard, including where and the degree of hazard Example statements are: - “Highly flammable liquid and vapor” - “Toxic if swallowed” - “Causes severe skin burns and eye damage”

25. Pictograms Definition: graphical composition that includes a symbol and other graphic elements, such as a border, background pattern or color that is intended to convey specific information

27. New Workplace Pictograms Characteristics: • Shape: square set at a point. Colors: • Background: white • Border: red • Symbol: black GHS pictogram for skin irritant !

28. (pg. 59)

29. Which Pictogram Am I ? (Exercise Follows)

30. Which Pictogram is 3. 2. 4. 5. YES 1. CORROSIVES? 6. 9. 7. 8.

31. Which Pictogram is 3. 2. 4. 5. 1. YES OXIDIZERS? 6. 9. 7. 8.

32. Which Pictogram 3. 2. 4. 5. 1. YES EMITS FLAMMABLE GAS? 6. 9. 7. 8.

33. Which Pictogram is 3. 2. 4. 5. 1. ACUTE/SEVERE TOXICITY? 6. YES 9. 7. 8.

34. Which Pictogram is 3. 2. 4. 5. 1. RESPIRATORY SENSITIZER? 6. YES 9. 7. 8.

35. Which Pictogram is 3. 2. 4. 5. 1. GASES UNDER PRESSURE? 6. YES 9. 7. 8.

36. Precautionary Statement Definition: phrases that describe recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or from improper storage or handling of a hazardous product

37. Precautionary Statementcontinued 4 types of precautionary statements: • Prevention(keep you from harm) • Response(steps to take if you have been exposed) • Storage(safe way to store) • Disposal(how to dispose of safely)

38. Is it a Precautionary or a Hazard Statement? PS • Keep away from heat/sparks/open flames/ hot surfaces • Self-heating in large quantities; may catch fire • Store in a well-ventilated place • Wear suitable protective clothing • Danger of serious damage to health by prolonged exposure HS PS PS HS

39. Supplementary Information • May include information such as: • PPE requirements for emergency response • Expiration/Fill dates • Directions for Use • Referrals to other sources of information

40. Sample Workplace Label Example GHS Inner Container Label (e.g., bottle inside a shipping box) ToxiFlam (Contains: XYZ)    Danger! Toxic If Swallowed, Flammable Liquid and VaporDo not eat, drink or use tobacco when using this product. Wash hands thoroughly after handling. Keep container tightly closed. Keep away from heat/sparks/open flame. - No smoking. Wear protective gloves and eye/face protection. Ground container and receiving equipment. Use explosion-proof electrical equipment. Take precautionary measures against static discharge. Use only non-sparking tools. Store in cool/well-ventilated place. IF SWALLOWED: Immediately call a POISON CONTROL CENTER or doctor/physician. Rinse mouth.In case of fire, use water fog, dry chemical, CO2, or "alcohol" foam. See Safety Data Sheet for further details regarding safe use of this product.MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999

41. Sample: Workplace Label 2 • Refer to handout of OXI252 • Note the pictograms

42. Sample: Workplace Label 3

43. GHS vs. HMIS vs. NFPA Labeling Numbering reflecting severity: GHS numbering system is completely opposite HMIS or NFPA labels. Neither of these systems will meet the new labeling requirements of the GHS! GHS Label                                   NFPA label HMIS Label

44. Example: A 1 in our current labeling system means slight hazard, whereas the 1 in the GHS system means high danger : warning of a serious hazard. (Serious hazard) *Note: GHS number/hazard category will not appear on labels, only in the SDS.

45. Online Resources 2012 ERG pdf and/or mobile app http://www.phmsa.dot.gov/hazmat/library/erg Dangerous Goods Manual mobile app -GHS workplace pictograms      

46. Location Where is your SDS book located?

47. Safety Data Sheets(pg. 58) 16-section detailed information bulletin • Employer will have one for each hazardous chemical used in order to develop worker protection measures • SDSs must be updated by chemical manufacturer within 6 months of new/significant information • SDSs are to be accessible to all employees

48. Contents of SDS • Section 1- Chemical Product and Company Identification • Section 2-Hazard Identification (organized by routes of entry) • Section 3- Composition, Information or Hazardous Ingredients • Section 4- First Aid Measures (organized by routes of entry) • Section 5- Fire and Explosion Hazard • Section 6- Accidental Release Measures • Section 7- Handling and Storage

49. Contents of SDScontinued • Section 8- Exposure Controls and PPE • Section 9- Physical & Chemical characteristics • Section 10- Stability and Reactivity Data • Section 11- Toxicological Information • Section 12- Ecological Information • Section 13- Disposal Considerations • Section 14- Transport Information • Section 15- Regulatory Information • Section 16- Other Information

50. Getting to Know the SDS You notice a strange odor when working with a new chemical. What section of the SDS will provide information about the odor? • Section 9- Physical & Chemical characteristics