GHS What does it really mean?

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Arleen Wilcox
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1 Oshkosh Safety Council Helping Keep Oshkosh Area Business & Industry Safe GHS What does it really mean? WAS RIGHT TO KNOW..NOW RIGHT TO UNDERSTAND

2 Current basic elements of a Hazard Communication Program. How and Why GHS was conceived. What are the elements of GHS. Review the GHS/HCS Alignment. Time line for implementation. What does it all mean.

3 What are the 5 Main elements of a compliant Hazard Communication Program? Chemical Inventory List (Hazard Classification) MSDS (Name is changed with GHS Alignment) Labeling (Changes for GHS Alignment) Employee Training No longer Right to Know But Right to Understand! Hazard Assessment for Non-Routine Tasks

The production and use of chemicals is fundamental to all economies. The global chemical business is more than a $1.7 trillion per year enterprise. In the U.S.

4 The production and use of chemicals is fundamental to all economies. The global chemical business is more than a $1.7 trillion per year enterprise. In the U.S., chemicals are more than a $450 billion business and exports are greater than $80 billion per year While the existing laws and regulations are similar, they are different enough to require multiple labels for the same product both within the U.S. and in international trade and to require multiple safety data sheets for the same product in international trade. Several U.S. regulatory agencies and various countries have different requirements for hazard definitions as well as for information to be included on labels or material safety data sheets.

5 Acute oral toxicity LD50 (mg/kg) High Hazard Low < to 500 > 2000 Hazard Category > 5000 Toxicity Category IV > 5000 Toxicity Rating 0 Organization/Country/ Regulation or Standard 0... < < < ANSI/US/A < 50 Highly Toxic > 50 < 500 Toxic > 500 < 2000 Harmful OSHA/US/HCS < 50 Highly Toxic > 50 < 500 Toxic EPA/US/FIFRA 0 50 Toxicity Category I > Toxicity Category II > 500 < 5000 Toxic Category III CPSC/US/FHSA < 50 Highly Toxic > Toxic GHS 5 > 5 50 > > > DOT/US < 5 Picking Group 1 > 5 < 50 Picking Group II > 50 < 200 (solid) > 50 > 500 (liquid) Picking Group III NFPA/US 5 Hazard Category 4 > 5 50 Hazard Category 3 > Hazard Category 2 > Hazard Category 1 NPCA/US/HMIS 1 Toxicity Rating 4 > 1 50 Toxicity Rating 3 > Toxicity Rating 2 > Toxicity Rating 1 EU < 25 Very Toxic > 25 > 200 Toxic > 200 < 2000 Harmful WHMIS/Canada 50 Very Toxic WHMIS Class D, Division 1, Subdivision A > Toxic WHMIS Class D, Division 1, Subdivision B Australia/NOHSC < 25 Very Toxic > 25 < 200 Toxic > 200 < 2000 Harmful <1 Extremely Toxic >20 < 50 Highly Toxic > 50 < 500 Moderately Toxic > 500 < 5000 Mildly Toxic

6 OSHA HCS Flammable = Degrees Combustible = degrees OSHA/NFPA Flammable = Degrees Combustible = degrees EU Extremely/Highly/Flammable = Degrees WHMIS (Canada) Division 2 Flammable = Degrees Division 3 Combustible = degrees DOT Flammable = Degrees Combustible = degrees IMO (Shipping Containers) International Maritime Organization Flammable = Degrees ICAO/IATA Flammable = Degrees CPSC (Consumer Products Safety) Flammable = Degrees Combustible = degrees ANSI Z129.1 Extremely Flammable = Degrees Combustible = degrees GHS Flammable = Degrees Combustible = degrees

7 Target Audiences Workplace Consumers Emergency Responders Transportation

8 The United Nations Conference on Environment and Development (UNCED) in 1992 addressed the need for global understanding of hazardous chemicals consistent for nation to nation. Sometimes called the EARTH SUMMIT. Scheduled to have been implemented by Y2K. OSHA updated Sub Part Z TOXIC & HAZARDOUS SUBSTANCES to align with GHS in March 16 th 2012 and became effective in May 25th 2012.

10 Hazard classification - Classification is the starting point for hazard communication - The term "hazard classification is used to indicate that only the intrinsic hazardous properties of substances and mixtures are considered and involves the following 3 steps: - a) Identification of relevant data regarding the hazards of a substance or mixture; - b) Subsequent review of those data to ascertain the hazards associated with the substance or mixture; and - c) A decision on whether the substance or mixture will be classified as a hazardous substance or mixture and the degree of hazard, where appropriate, by comparison of the data with agreed hazard classification criteria.

11 Hazard classification Provides specific criteria for classification of health, physical hazards, as well as classification of mixture, (See Appendix A & B of ) and Environmental Hazards. The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area( Not covered in GHS but addressed by OSHA)

12 Hazard classification Physical Maintains the same basic evaluation and physical properties of HCS. a gas is a substance or mixture which at 50 C has a vapor pressure greater than 300 kpa; or is completely gaseous at 20 C and a standard pressure of kpa. a liquid is a substance or mixture that is not a gas and which has a melting point or initial melting point of 20 C or less at standard pressure of kpa. a solid is a substance or mixture that does not meet the definitions of a liquid or a gas.

13 Physical 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 Hazard classification

14 Hazard classification Health 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

15 MIXTURES: Hazard classification - (1) Where test data are available for the mixture itself, the classification of the mixture will be based on that data (See exception for carcinogens, mutagens & reproductive toxins in the GHS Document), - (2) Where test data are not available for the mixture itself, then the appropriate bridging principles should be used; - (3) If test data are not available for the mixture itself, and the bridging principles cannot be applied, then use the calculation or cutoff values described in the specific endpoint to classify the mixture.

16 Hazard classification MIXTURES: Bridging Principals - Dilution: If a mixture is diluted with a diluent that has an equivalent or lower toxicity, then the hazards of the new mixture are assumed to be equivalent to the original. Batching: If a batch of a complex substance is produced under a controlled process, then the hazards of the new batch are assumed to be equivalent to the previous batches. - Concentration of Highly Toxic Mixtures: If a mixture is severely hazardous, then a concentrated mixture is also assumed to be severely hazardous - Interpolation within One Toxic Category: Mixtures having component concentrations within a range where the hazards are known are assumed to have those known hazards. - Substantially Similar Mixtures: Slight changes in the concentrations of components are not expected to change the hazards of a mixture and substitutions involving toxicologically similar components are not expected to change the hazards of a mixture - Aerosols: An aerosol form of a mixture is assumed to have the same hazards as the tested, non-aerosolized form of the mixture unless the propellant affects the hazards upon spraying

17 Safety Data Sheets Identification Hazard(s) identification Composition/information on ingredients First-aid measures Fire-fighting measures Accidental release measures Handling and Storage Exposure controls/personal protection Physical and chemical properties Stability and reactivity Toxicological information Ecological information Disposal considerations Transport information Regulatory information Other information

18 Label Elements f)(1)(i) Product identifier; (f)(1)(ii) Signal word; (f)(1)(iii) Hazard statement(s); (f)(1)(iv) Pictogram(s); (f)(1)(v) Precautionary statement(s); and, (f)(1)(vi) Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.

19 Label Elements PRODUCT IDENTIFER: Name of Hazard Should match the Safety Data Sheet Can include things like CAS number

20 Label Elements Signal Word DANGER WARNING

21 Hazard Statements: Physical H200: Unstable explosive H201: Explosive; mass explosion hazard H202: Explosive; severe projection hazard H203: Explosive; fire, blast or projection hazard H204: Fire or projection hazard H205: May mass explode in fire H220: Extremely flammable gas H221: Flammable gas H222: Extremely flammable material H223: Flammable material H224: Extremely flammable liquid and vapor H225: Highly flammable liquid and vapor H226: Flammable liquid and vapor H227: Combustible liquid H228: Flammable solid H240: Heating may cause an explosion H241: Heating may cause a fire or explosion H242: Heating may cause a fire H250: Catches fire spontaneously if exposed to air H251: Self-heating; may catch fire H252: Self-heating in large quantities; may catch fire H260: In contact with water releases flammable gases which may ignite spontaneously H261: In contact with water releases flammable gas H270: May cause or intensify fire; oxidizer H271: May cause fire or explosion; strong oxidizer H272: May intensify fire; oxidizer H280: Contains gas under pressure; may explode if heated H281: Contains refrigerated gas; may cause cryogenic burns or injury H290: May be corrosive to metals

22 Hazard Statements: Health H300: Fatal if swallowed H301: Toxic if swallowed H302: Harmful if swallowed H303: May be harmful if swallowed H304: May be fatal if swallowed and enters airways H305: May be harmful if swallowed and enters airways H310: Fatal in contact with skin H311: Toxic in contact with skin H312: Harmful in contact with skin H313: May be harmful in contact with skin H314: Causes severe skin burns and eye damage H315: Causes skin irritation H316: Causes mild skin irritation H317: May cause an allergic skin reaction H318: Causes serious eye damage H319: Causes serious eye irritation H320: Causes eye irritation H330: Fatal if inhaled H331: Toxic if inhaled H332: Harmful if inhaled H333: May be harmful if inhaled H334: May cause allergy or asthma symptoms or breathing difficulties if inhaled H335: May cause respiratory irritation H336: May cause drowsiness or dizziness H340: May cause genetic defects H341: Suspected of causing genetic defects H350: May cause cancer H351: Suspected of causing cancer H360: May damage fertility or the unborn child H361: Suspected of damaging fertility or the unborn child H362: May cause harm to breast-fed children H370: Causes damage to organs H371: May cause damage to organs H372: Causes damage to organs through prolonged or repeated exposure H373: May cause damage to organs through prolonged or repeated exposure

23 ACUTE ORAL TOXICITY - Annex 1 Category 1 Category 2 Category 3 Category 4 Category 5 LD 50 5 mg/kg > 5 < 50 mg/kg ³ 50 < 300 mg/kg ³ 300 < 2000 mg/kg ³ 2000 < 5000 mg/kg Pictogram No symbol Signal word Hazard statement Danger Danger Danger Warning Warning Fatal if swallowed Fatal if swallowed Toxic if swallowed Harmful if swallowed May be harmful if swallowed

24 GHS Pictograms and Hazard Classes Oxidizers Flammables Self Reactives Pyrophorics Self-Heating Emits Flammable Gas Organic Peroxides Explosives Self Reactives Organic Peroxides Acute toxicity (severe) Corrosives Gases Under Pressure Carcinogen Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity Aspiration Toxicity Environmental Toxicity Irritant Dermal Sensitizer Acute toxicity (harmful) Narcotic Effects Respiratory Tract Irritation

26 (j) Effective dates. (j)(1) Employers shall train employees regarding the new label elements and safety data sheets format by December 1, (j)(2) Chemical manufacturers, importers, distributors, and employers shall be in compliance with all modified provisions of this section no later than June 1, 2015, except: (j)(2)(i) After December 1, 2015, the distributor shall not ship containers labeled by the chemical manufacturer or importer unless the label has been modified to comply with paragraph (f)(1) of this section. (j)(2) (ii) All employers shall, as necessary, update any alternative workplace labeling used under paragraph (f)(6) of this section, update the hazard communication program required by paragraph (h)(1), and provide any additional employee training in accordance with paragraph (h)(3) for newly identified physical or health hazards no later than June 1, (j)(3) Chemical manufacturers, importers, distributors, and employers may comply with either , revised as of October 1, 2011, or the current version of this standard or both during the transition period

27 What does all this mean! (j)(1) Employers shall train employees regarding the new label elements and safety data sheets format by December 1, (j)(2) (ii) All employers shall, as necessary, update any alternative workplace labeling used under paragraph (f)(6) of this section, update the hazard communication program required by paragraph (h)(1), and provide any additional employee training in accordance with paragraph (h)(3) for newly identified physical or health hazards no later than June 1, 2016 (f)(6) Workplace labeling. Except as provided in paragraphs (f)(7) and (f)(8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either: f)(6)(i) The information specified under paragraphs (f)(1)(i) through (v) of this section for labels on shipped containers; or, f)(6)(ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical. (h)(1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets h)(3) Training. Employee training shall include at least: (h)(3)(i) Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.); (h)(3)(ii) The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area; (h)(3)(iii) The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; and, (h)(3)(iv) The details of the hazard communication program developed by the employer, including an explanation of thelabels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.

29 OSHA Tim Braun Compliance Officer/CIH Appleton Office

ANNEX 1 ALLOCATION OF LABEL ELEMENTS

ANNEXES - 229 - ANNEX 1 ALLOCATION OF LABEL ELEMENTS - 231 - Annex 1 ALLOCATION OF LABEL ELEMENTS For the GHS, the assigned pictogram, signal word and hazard statement are given in that order for each