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Hazard Communication. Brodie Loushin PayneWest. The Purpose of the Hazard Communication Standard (HCS) . Reduce illness and injuries related to hazardous chemical exposures Evaluate hazardous chemical usage and storage at our facilities
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Hazard Communication Brodie Loushin PayneWest
The Purpose of the Hazard Communication Standard (HCS) • Reduceillness and injuries related to hazardous chemical exposures • Evaluate hazardous chemical usage and storage at our facilities • Communicate information to employees, emergency responders, and contractors about the hazardous chemicals used at, or brought into, our facilities • Reduce quantities of hazardous waste disposal fees due to unused products left at or past their prime use condition
WORKPLACE CHEMICALSPut Everyone At Risk • Employees are exposed to hazardous chemicals everyday! • NIOSH research indicates that up to 50% of asthma patients have exacerbated pre-existing asthma through exposure to workplace chemicals. Acute Exposure Chronic Exposure
Material Safety Data Sheets (MSDS) • Developed by Chemical manufacturers and importers • Distributors transfer to customers • Includes information regarding hazards associated with the product • Employers maintain a copy onsite • Electronic or hard copies of MSDS must be reasonably available • MSDS records must be maintained for 30 years after the product has been used.
Material Safety Data Sheets (MSDS) • Required by law except for: • Food • Drugs • Cosmetics • Tobacco or tobacco products • Wood or wood products • Treated wood or wood intended for subsequent cutting/dust generation is not exempt • Biological hazards • Nuisance particulates • Ionizing and non-ionizing radiation • Over the shelf products in quantities a consumer would have – AKA one or two bottles • Hazardous waste covered by RCRA • Hazardous substances covered by CERCLA (removed/remediated substances)
MSDS • Must include some basic information • Name, address and phone number of the manufacturer • Identity used on the label • Chemical and common name • Physical and chemical characteristics • Physical hazards • Primary route of entry • PEL/TLV • If it is a carcinogen • Safe handling procedures • Control measures • Emergency & first aid information • Date of preparation
Name, address and phone number of manufacturer Identity use on the label Date of preparation Physical Hazards Primary route of entry Carcinogen information Chemical names of ingredients Emergency and First Aid
Control measures Safe handling precautions PEL/TLV
More control procedures Physical/chemical characteristics Environmental
4 1 0 Labeling
What does it all mean? • Don’t swallow it • If you do, don’t vomit • Don’t spray it in your eyes • If you do flush with water • Best to look at the direction of the arrow on top of spray button • Don’t use in confined spaces without proper ventilation • Avoid skin contact • If you do, wash with soap and water • It is flammable • Don’t store it by the furnace • Don’t spray it into the flames • Don’t let it touch the battery terminals • An ABC extinguisher is fine to extinguish a fire • Leaking cans • Put them in a bucket until pressure is dispersed • Clean up any spills with pig pads • Store in flammable cabinet • In vehicles care should be taken to not store in direct sun and avoid temps over 120o
Caution • Consider how the manufacturer intended the product to be used • Fertilizer used in small quantities is not harmful to plants • Consider the quantity of the product being used • One can of WD-40 verses a facility where they are manufacturing the cans of WD-40 • Consider the controls in place when using the product • Natural gas is a hazard when not controlled by design. We cook our food and heat our homes safely when natural gas is controlled.
Implementing Hazard Communication Programs • Chemical inventory • Hazard evaluation • Communication of hazards to employees and contractors • Labeling of containers including piping systems • Training
Chemical Groups • Solvents, Strippers, and Degreasers • Paints, Coatings, and Resins • Adhesives, Sealants, and Cement • Pesticides, Insecticides and Herbicides • Fuels and Fuel Additives • Lubricants, Hydraulic and Cutting Fluids • Cleaners and Detergents • Compressed Gas • Insulating Materials, Abrasives and Packing • Corrosives • Coolants • Metals and Fluxes for Welding and Melting • Other Chemicals and Specialty Chemicals • Water Treatment Chemicals
Hazard Evaluation • By reading the MSDS a hazard evaluation can take place based on the chemicals in the product and how it is used • Use the MSDSonline system to identify hazard warning labels on secondary containers • Monitoring can also be used to evaluate exposure risks
Labeling • Identification of chemical • Warning labels • Name and address of manufacturer/distributor • Legible • In English • Prominently displayed • Secondary containers
Secondary Containers • Must be labeled unless • Immediately used by person making transfer • Under the control of the person making the transfer • Examples: • Transfer paint from a five gallon container to a quart sized container for quick paint touch up activities • Quart must be labeled unless product is used up at the end of the workday or when not under the control of the employee who transferred it • Transfer five gallons of oil from a 55 gallon barrel • Five gallon container must be labeled
Training • Understand hazards of chemicals you are exposed to • Understand the MSDS • Understand your responsibilities to communicate hazards to others • Understand your responsibilities to label containers and piping systems • Understand what is required on a label • Understand the company’s electronic MSDS system
Break GHS next
Globally Harmonized System (GHS) What is the GHS? • GHS is a world-wide standardized approach to hazard communication • supported by the United Nations and regulatory agencies around the globe, including OSHA. • GHS can be summarized into three main components: • Standardized hazardous chemical classifications • Standardized hazard warnings and symbols on container labels • Standardized MSDS format and content (SDS)
GHS Phase-in Period What is the phase-in period? • December 1, 2013: Employers required to train employees on the new label elements and safety data sheet (SDS) format. • June 1, 2015: Chemical manufacturers, importers, distributors and employers required to be in compliance with all modified provisions of this final rule, except: • December 1, 2015: The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label
GHS Phase-in Period cont’d • June 1, 2016: Employers required to update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. • During the phase-in period, employers are required to be in compliance with either the existing Hazard Communication Standard (HCS) or the revised HCS, or both. • OSHA recognizes there will be a period of time where labels and SDSs under both standards will be present in the workplace. • This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.
GHS: Three major areas of change • Hazard classification:The current HCS is a performance-oriented approach that provides parameters for the evaluation, but not specific, detailed criteria. The revised HCS has specific criteria for each health and physical hazard, along with detailed instructions for hazard evaluation and determinations as to whether mixtures or substances are covered. • 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.
GHS: Hazard Classification • Three main hazard classifications: • Physical Hazards • Health Hazards • Environmental Hazards
GHS: Hazard Classification Physical Hazards: • Explosives • Flammable Gases • Flammable Aerosols • Oxidizing Gases • Gases Under Pressure • Flammable Liquids • Flammable Solids • Self-Reactive Substances • Pyrophoric Liquids • Pyrophoric Solids • Self-Heating Substances • Substances which, in contact with water emit flammable gases • Oxidizing Liquids • Oxidizing Solids • Organic Peroxides • Corrosive to Metals
GHS: Hazard Classification • Health Hazards • Acute Toxicity • Skin Corrosion/Irritation • Serious Eye Damage/Eye Irritation • Respiratory or Skin Sensitization • Germ Cell Mutagenicity • Carcinogenicity • Reproductive Toxicology • Target Organ Systemic Toxicity - Single Exposure • Target Organ Systemic Toxicity - Repeated Exposure • Aspiration Toxicity
GHS: Hazard Classification • Environmental Hazards • Hazardous to the Aquatic Environment • Acute aquatic toxicity • Chronic aquatic toxicity • Bioaccumulation potential • Rapid degradability • Environmental hazards are not within OSHA's jurisdiction
GHS: Labels How will labels change? • Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the HCS. • Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards. • Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. Example: Fatal if swallowed • Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical. Addresses prevention, response, storage, disposal.
Precautionary Statement Examples • Prevention • Wash hands thoroughly after handling • Response • If swallowed: Immediately call a poison center/doctor • Storage • Store in well-ventilated place. Keep cool. • Store locked up • Disposal • Dispose of content/container in accordance with local/regional/national/international regulations
GHS: Labels • Q. Can I use a black border on pictograms for domestic shipment? • A. Under the revised Hazard Communication Standard (HCS), pictograms must have red borders. • OSHA believes that the use of the red frame will increase recognition and comprehensibility. Therefore, the red frame is required regardless of whether the shipment is domestic or international.
GHS: Labels • Q. Will OSHA allow blank red borders? • A. The revised HCS requires that all red borders printed on the label have a symbol printed inside it. • If OSHA were to allow blank red borders, workers may be confused about what they mean and concerned that some information is missing. • OSHA has determined that prohibiting the use of blank red borders on labels is necessary to provide the maximum recognition and impact of warning labels and to ensure that users do not get desensitized to the warnings placed on labels.
GHS: Labels • Q. When must label information be updated? • A. In the revised HCS, OSHA is lifting the stay on enforcement regarding the provision to update labels when new information on hazards becomes available. • Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information. • If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.
GHS: Labels • Q. How will workplace labeling provisions be changing under the revised Hazard Communication Standard? • A. The current standard provides employers with flexibility regarding the type of system to be used in their workplaces and OSHA has retained that flexibility in the revised HCS. • Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard. • Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers. • However, the information supplied on these labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms.
GHS: Safety Data Sheet (SDS) • The format of the 16-section SDS should include the following sections: • Section 1. Identification • Section 2. Hazard(s) identification • 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 • Section 12. Ecological information • Section 13. Disposal considerations • Section 14. Transport information • Section 15. Regulatory information • Section 16. Other information, including date of preparation or last revision
Hazard Communication Quiz Question 1 How can you access a MSDS for a product? A. Notebook on Shelf • B. Internet • C. Safety Specialist • D. All of the above
Hazard Communication Quiz Question 2 Why should containers be labeled? A. It is a regulatory requirement B. They look nice C. Everyone will know what it contains D. A and C
Hazard Communication Quiz Question 3 What is the most common chemical that you are potentially exposed to on the job? A. Oil B. Welding fume C. Methane D. Solvent
Hazard Communication Quiz Question 4 True or False • A label must be legible. • The manufacturer’s name and address must be on the secondary container label. • Piping systems are exempt from the Hazard Communication Standard.
Hazard Communication Quiz Question 5 True or False • The GHS is a world-wide standardized approach to hazard communication. • The GHS stands for Globally Harmed Situation. • The GHS will standardize hazardous chemical classifications. • The GHS will standardize hazard warnings and symbols on container labels. • The MSDS format and content will not change.
Hazard Communication Quiz Question 6 • During the GHS phase-in period, what is required to be completed by: • December 1, 2013 • June 1, 2015 • December 1, 2015 • June 2, 2016
Hazard Communication Quiz Question 7 • Can I use a black border on pictograms for domestic shipment? Question 8 • Will OSHA allow blank red borders? Question 9 • How many sections are required for the SDS?
Hazard Communication Quiz • Match the Pictogram to the appropriate title Break – MSDSonline next