4/10/2013. Wisconsin Council of Safety Kay Rowntree, CIH Industrial Hygiene Sciences, LLC April 2013

Transcription

1 Wisconsin Council of Safety Kay Rowntree, CIH Industrial Hygiene Sciences, LLC April 2013 The Globally Harmonized Systemof Classification and Labeling of Chemicals A system for standardizing and harmonizing the classification and labeling of chemicals Not a regulation, not a treaty obligation Roots are in a 1992 UN mandate Builds on the best of existing regulations in the US, EU, Canada and the UN Transport Regulations Defining the health, physical and environmental hazards of chemicals; Classifying hazards Communicating hazard information and protective measureson labels and Safety Data Sheets (SDS) 1

2 Make everything the same in all countries Countries can choose to adopt all or some of the GHS building blocks Change existing environmental, consumer and other regulations. Globally there are differences in.. What chemicals are covered What has to be included on an SDS What has to be on a label Disclosure requirements Language requirements 2

3 Alignedthe existing Hazard Communication Standard which was last revised in 1994 with GHS in March, 2012 Adopted most of GHS Added some classes not covered under GHS Addressed some hazards not covered under GHS Established dates for compliance with the changes What has OSHA learned after their publication & outreach efforts? People still didn t understand Hazard Communication 1994! The HCS is and has been one of the most frequently cited OSHA standards There are many misunderstandings about what is required Maintenance of a program is required GHS will not solve these problems What has changed terminology hazard definitions labeling requirements MSDSs (SDSs) format What has not changed the goals & basic requirements of the HCS definition of an article the requirement that manufacturers, importers or distributors produce SDSs and labels the requirement that chemical users obtain SDSs the need to train employees 3

4 Flammable and Combustible Liquids ( and ) Process Safety Management of Highly Hazardous Chemicals ( ) Other standards-sections on labeling, signs and SDSs were changed to align with GHS Welding, cutting & Brazing ( ) Asbestos, arsenic, lead, cadmium, hexavalent chromium and other substance specific standards Lab standard If you are affected by these standards, review the changes issued Goals Original HCS= the right to know Aligned HCS= the right to understand Elements of a Program for Chemical Users Do a chemical inventory Prepare a written program Ensure containers are labeled Collect/manage MSDSs Inform and train employees Address contractor exposure Do you sell covered products to others who use them in the workplace? You may be surprised to find that you do. You WILL have to redo your MSDSs You WILL have to change labels A competent person who understands industrial hygiene, toxicology, chemistry should do the classification Software programs exist to aid in classification but require the above knowledge to use properly You need a plan now! 4

5 SDS Safety Data Sheet Product Identifier formerly called Product Name Hazard group Health Physical Environmental (not enforced by OSHA) GHS Terminology Class Describes the intrinsic hazard(s) of a substance Within each classes there are rules(criteria) for classification Each hazard group has its own list of classes Category Describes in more detail the nature of the hazard(s) within a class Each category has rules(criteria) for classification The information provided generally reflects the degree of severity of the hazard GHS Terminology-Hazard Statements Short statements about the hazard(s) Standardized language Based on the classification Must appear on the label and on the SDS Numerical codes describe hazards but they do not have to appear on the label 5

6 Phrases and/or pictograms that describe what measures should be taken to prevent adverse effects Covers personnel, storage or handling related protection Based on the classification Numerical codes describe precautions but they do not have to appear on the label GHS Terminology-Signal Word Communicates the level of hazard Only 2 signal words-danger and Warning Choice is based on the classification Must be on the label and SDS There are classifications in which no signal word is required A standardized visual symbol that conveys the potential hazard(s) Must be on the label and SDS Choice(s) are based on the classification There are classifications for which no pictogram is required These are not the same as the PPE pictograms often seen on current MSDSs and labels 6

7 December 1, 2013-employers must train or retrain employees regarding new label elements and SDS format June 1, 2015-all labels and SDSs must be updated by chemical manufacturers, distributors or importers Distributors have an additional 6 months to distribute containers with manufacturers labels to accommodate containers received close to the compliance date June 1, 2016-employers have to update their Haz Com program and signs The nuts and bolts of the HCS requirements have not changed Each chemical s health/physical hazards must be classified according to the GHS criteria Each hazard class & category has a harmonized Signal Word Pictogram(s) Hazard Statement(s) Precautionary Statement(s) These must be on SDSs and labels 7

8 The definitions of hazards in GHS are more specific and detailed than those in the old HCS Chemical manufacturers must review the pertinent scientific data to assess hazards This has always been a part of Haz Com but often is poorly done The GHS system is heavily influenced by a European approach to hazards There can be many categories within a class The lower the category #, the greater the risk 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 Liquids having a flash point of not more than F 4 Categories Category Criteria 1 Flash point < 23 C C (73.4 F) & initial boiling point 35 C C (95 F) 2 Flash point < 23 C C (73.4 F) & initial boiling point > 35 C C (95 F) 3 Flash point 23 C C (73.4 F) and 60 C C (140 F) 4 Flash point > 60 C C (140 F) and 93 C C (199.4 F) 8

9 Acute Toxicity Effects that occur following single dose or multiple doses within 24 hours (oral/dermal) or an inhalation dose of 4 hours OSHA adopted 4 categories in each route Skin Corrosion & Irritation Corrosion is irreversible damage to the skin or corrosion of the skin (ulcers, bleeding, bloody scabs, scars, etc) Three sub-categories based on time it takes to cause damage Irritation Reversible damage to the skin Outcomes include redness, edema, inflammation One category Serious Eye Damage/Eye Irritation Serious-Tissue damage to the eye or serious decay of vision that is not fully reversible within 21 days 1 category (Category 1) Irritation-changes to the eye which are full reversible within 21 days 2 categories Sensitizers Respiratory- can lead to hypersensitivity of the airways 2 categories separated by the frequency at which the chemicals has the potential to cause sensitization (high or low/moderate) There are mixture cut-offs Skin-allergic responses following skin contact 2 sub-categories separate by frequency (see above) There are mixture cut-offs Germ Cell Mutagenicity Permanent change in the amount or structure of the genetic material in a cells 2 categories-known, could cause and cause concern There are mixture cutoffs Reproductive Adverse effects on sexual function & fertility in adults development of offspring lactation 4 Categories-known, presumed, suspected and lactation There are mixture cutoffs 9

10 Induces cancer or increases its incidence Can use data from well-performed animal studies Categories 1A= known to have carcinogenic properties to humans 1B= presumed to have carcinogenic properties for humans 2= Suspected human carcinogens-based on strength of evidence If the weight of evidence doesn t meet the criteria but there is a well done positive study, it must be noted Mixture cutoffs 0.1% for 1A/1B and 1% for category 2 Chronic health hazard pictogram STOT=Specific Target Organ Toxicity Specific non-lethal target organ effects Applies to all health effects that can impair function Reversible or irreversible Immediate and/or delayed Can occur by any route of exposure Not specifically addressed in the previous health hazard classes 2 STOT classes-single (STOT-SE) & repeated/prolonged (STOT-RE) STOT-SE Arise from a singleexposure 3 categories 1= Have produced significant toxicity 2= Have the potential to produce 3- Produce transient target organ effects STOT-RE Follows repeated or prolonged exposure 2 categories 1= Have produced significant toxicity 2= Have the potential to produce 10

11 Not covered under GHS but OSHA added it Entry of liquid or solid into the trachea and lower respiratory tract Direct through mouth or nose Indirect from vomiting 1 category based on a formula for kinematic viscosity The health hazard pictogram is used Signal word is Danger or Warning Simple asphyxiants Must be addressed on SDSs & labels Signal word=warning Hazard Statement: May displace oxygen and cause rapid suffocation Combustible dusts Must be addressed on SDSs and labels Signal word=warning Hazard Statement: May form combustible dust concentrations in the air Hazardous to the aquatic environment (acute and chronic) Hazardous to the ozone layer OSHA has no jurisdiction over these so they cannot require them under HCS 11

12 A statement assigned to a hazard class and category Describes the nature of the hazards of a chemical, including, where appropriate, the degree of hazard. 72 individual and 17 combined Will replace EU R phrases seen on European SDSs Causes eye irritation Causes mid skin irritation Causes serious eye damage Causes serious eye irritation Causes severe skin burns and eye damage Causes skin irritation Combustible liquid Contains gas under pressure; may explode if heated Contains refrigerated gas; may cause cryogenic burns or injury Explosion; fire, blast or projection hazard Explosion; mass explosion hazard Explosion; severe projection hazard Extremely flammable aerosol Extremely flammable gas Extremely flammable liquid and vapour Fatal if inhaled Fatal if swallowed Fatal in contact with skin Fire or projection hazard Flammable aerosol Flammable gas Flammable liquid and vapour Flammable solid Harmful if inhaled Harmful if swallowed 12

13 A statement assigned to a hazard class and category Describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling. Types of Precautionary Statements General Prevention Response in case of spill or exposure Storage Disposal 116 individual & 33 combined Obtain special instructions before use Do not handle until all safety precautions have been read and understood Keep away from heat/sparks/open flames/hot surfaces No smoking Do not spray on an open flame or other ignition source Do not allow contact with air Keep away from any possible contact with water, because of violent reaction and possible flash fire Protect from moisture Keep container tightly closed Ground/bond container and receiving equipment Use only non-sparking tools Take precautionary measures against static discharge Do not breathe dust/fume/gas mist/vapours/spray Use only outdoors or in a well-ventilated area Used to indicate the relative level of severity of hazard Choice is driven by the hazard classification and category Only 2 'Danger' is used for more severe hazard(s) Warning' is used for less severe hazard(s) Some classes have no Signal Word 13

14 Labels must be in English legible prominently displayed Portable container exemption still applies Container definition Pipes, piping systems, engines & fuel tanks or other operating systems in a vehicle are not considered containers Manufacturers must label their products Users must ensure labels are not defaced in-plant containers are labeled train employees how to read labels Shipped container required elements Product identifier (must match the SDS) Supplier information Pictograms Signal Words Hazard statements Precautionary statements Supplemental info allowed but can t contradict GHS Pictograms must follow GHS requirements and have a red border OSHA cannot require the pictogram for environmental hazards but you will still probably see it on labels The precedence of the Signal Words, Pictogram is defined Appendix C describes label requirements DOT and GHS 14

15 From: Label updates Must be done within 6 months after receipt of info that hazards have changed; any chemicals shippedafter that time musthave the new labels Distributors get additional time to move existing stock For solid metal, wood or plastic items that are not excluded as articles (f)(4)(i) the required label can be transmitted at time of the initial shipment does not need to be included in subsequent shipment unless info on the label changes only applies to the solid material itself this label exclusion does not apply if there are other hazardous substances used in conjunction with or present with the item to which downstream users may be exposed Workplace containers must be labeled with same label that is on shipped container for the chemical OR use label alternatives that meet the requirements of the standard Any alternative systems can t have pictograms or signal words that conflict with GHS 15

16 History of these labeling systems Labels on their own too generic Effective only if the overall HCS program is effective Employer bears the burden of establishing that employees are aware & know what to do Numbering issues Category numbers only needed on SDSs Category numbers do not correlate directly to the HMIS label numbers Physical hazards will be easier to assign The goal is to convey information about the hazard so employees taken the proper precautions If you use info other than the shipped container are you causing confusion? If the label does not contain and convey the info needed to work safely, then you have to training and ensure employees to understand the hazards 16

17 What is It? Exploding Bomb Pictogram Hazard Class/Category Unstable explosives Explosives of Divisions 1.1, 1.2, 1.3, 1.4 Self reactive substances and mixtures, Types A,B Organic peroxides, Types A,B Flame Flammable gases, category 1 Flammable aerosols, categories 1,2 Flammable liquids, categories 1,2,3 Flammable solids, categories 1,2 Self-reactive substances and mixtures, Types B,C,D,E,F Pyrophoric liquids, category 1 Pyrophoric solids, category 1 Self-heating substances and mixtures, categories 1,2 Substances and mixtures, which in contact with water, emit flammable gases, categories 1,2,3 Organic peroxides, Types B,C,D,E,F What is It? Pictogram Hazard Class/Category Flame over a Circle Oxidizing gases, category 1 Oxidizing liquids, categories 1,2,3 Cylinder Gases under pressure: -Compressed gases -Liquefied gases - Refrigerated liquefied gases - Dissolved gases Corrosion Corrosive to metals, category 1 Skin corrosion, categories 1A,1B,1C Serious eye damage, category 1 Skull & Crossbones Acute toxicity (oral, dermal, inhalation), categories 1,2,3 What is It? Exclamation Point Health Hazard Dead fish and tree Pictogram Hazard Class/Category Acute toxicity (oral, dermal, inhalation), category 4 Skin irritation, category 2 Eye irritation, category 2 Skin sensitisation, category 1 Specific Target Organ Toxicity Single exposure, category 3 Respiratory sensitization, category 1 Germ cell mutagenicity, categories 1A,1B,2 Carcinogenicity, categories 1A,1B,2 Reproductive toxicity, categories 1A,1B,2 Specific Target Organ Toxicity Single exposure, categories 1,2 Specific Target Organ Toxicity Repeated exposure, categories 1,2 Aspiration Hazard, category 1 Hazardous to the aquatic environment - Acute hazard, category1 - Chronic hazard, categories 1,2 17

18 When you see (pictogram), do this! Then explain what this is 18

19 Required to do a chemical inventory Common oversights not including articles that could generate hazards during expected use of product missing items bought at local stores samples provided by vendors household/consumer products used in a manner beyond range of exposures experienced by consumers Manufacturers follow hazard criteria (now classification) in preparation be accurate and complete in English provide to downstream users at initial shipment & updates update & distribute when new info becomes available Users obtain and maintain if document is the only source of chemical info, archive for 30 years after end use date ) make them accessible at all times (no barriers) train employees in how to use them Listings IARC or NTP carcinogens above cut-off level OSHA PELs and ACGIH TLVs OSHA permits electronic documents but there should be a back-up plan if computer system fail Should be a back-up system paper documents fax-back service computer back-up to an unaffected computer/hard drive auxiliary power system Must be able to product a paper document immediately if an employee or OSHA requests one 19

20 16 part format essentially same as ANSI Sections must be in the order listed in the following slides Several sections will not be made mandatory by OSHA (Sections 12-15) since they do not deal with workplace H & S If no relevant info is found for any Physical Hazard subheading, then it must be marked as no applicable information found-cannot omit Section 1-Identification Product identifier Other means of identification Recommended use of the chemical and restrictions on use Supplier's details (including name, address, phone number, etc.) Emergency phone number Section 2-Hazards Identification GHS classification GHS label elements, including precautionary statements, signal words & pictograms (red border not required on the SDS) Hazards not otherwise classified Supplementary hazard information Substance/ Chemical identity Common name, synonyms, etc. CAS # Impurities and stabilizing additives which are themselves classified and which contribute to the classification of the substance For mixtures the chemical identity and concentration or concentration ranges of all ingredients which are hazardous within the meaning of the GHS and are present above their cutoff levels Trade Secrets-A statement that the specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a trade secret 20

21 Section 4: First Aid Measures Description of necessary measures, subdivided according to the different routes of exposure, i.e., inhalation, skin and eye contact, and ingestion Most important symptoms/effects, acute and delayed Indication of immediate medical attention and special treatment needed, if necessary Section 5: Fire Fighting Measures Suitable (and unsuitable) extinguishing media Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products, dust combustibility) Special protective equipment and precautions for firefighters Section 6: Accidental Release Measures Personal precautions, protective equipment and emergency procedures Environmental precautions Methods and materials for containment and cleaning up Section 7: Handling and Storage Precautions for safe handling Conditions for safe storage, including any incompatibilities Section 8: Exposure Controls/Personal Protection Control parameters Occupational exposure limit values including OSHA PELs, ACGIH TLVs or manufacturers limits Appropriate engineering controls Individual protective measures, such as personal protective equipment (PPE) Appearance (physical state, color, etc.) Odor Odor threshold ph Melting point/freezing point Initial boiling point & boiling range Flash point Evaporation rate Flammability (solid, gas) Upper/lower flammability or explosive limits Vapor pressure Vapor density Relative density Solubility(ies) Partition coefficient: n- octanol/water Autoignition temperature Decomposition temperature 21

22 Section 10: Stability & Reactivity Reactivity Chemical stability Possibility of hazardous reactions Conditions to avoid (e.g., static discharge, shock, or vibration) Incompatible materials Hazardous decomposition products Section 11-Toxicological Information Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact) Symptoms related to the physical, chemical and toxicological characteristics Delayed and immediate effects and also chronic effects from short-and long-term exposure Numerical measures of toxicity (such as acute toxicity estimates) Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest edition), or by OSHA. Section 12: Ecological Info Ecotoxicity (aquatic and terrestrial, where available) Persistence and degradability Bioaccumulative potential Mobility in soil Other adverse effects Section 13: Disposal Considerations Description of waste residues and information on their safe handling and methods of disposal, including the disposal of any contaminated packaging Section 14-Transport Info UN Number UN Proper shipping name Transport Hazard class(es) Packing group, if applicable Marine pollutant (Yes/No) Special precautions which a user needs to be aware of or needs to comply with in connection with transport or conveyance either within or outside their premises Section 15: Regulatory Info Safety, health and environmental regulations specific for the product in question Section 16: Other information including date of preparation or last change Sections will not be enforced by OSHA Two sets of books do not have to be kept Manufacturers do not have to provide SDSs for previous purchasers or products it no longer makes or distributes If you do not get a compliant SDS by the deadline, employers must make attempts to obtain the document 22

23 Training Deadline: December 1, 2013-How to read SDS and GHS labels Problem Training may not be the solution Training too generic Training format is not appropriate Poor transfer of learning Can t prove training was done One size fits all Trainer is not comfortable with the training Solutions Control or eliminate hazard Avoid or supplement canned programs Break into smaller pieces & understand how adults learn Follow-up, coaching and holding employees & supervisors accountable Keep records of training methods, tools, attendance Know your audience Develop their skills, split training up, have training done by someone else Employers should provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenevera new physical or health hazard that employees have not been previously trained about is introduced into their work area 23

24 Effective The training must go from the classroom to their job Employees should know where hazardous chemicals are in their work area(s) how they can protect themselves In their work area General knowledge is not sufficient Address what will actually be encountered Time of initial assignment This means BEFORE they encounter the exposure Newhazard New introduction to the job Employee moves to a job with different hazards Information and training may be designed to cover categoriesof hazards (such as flammability or carcinogenicity) or specific chemicals. Chemicalspecific information must always be available through labels and material safety data sheets. Categories of hazards OSHA does not expect separate training for each chemical Chemicals can be grouped into categories and employees can be informed of the hazards and protective measures for that category Easier to do with physical hazards than health hazards Examples Flammables Corrosives Oxidizers Specific chemicals those that don t belong in a category need to be singled out for some other reason may present a special hazard are present in great quantities Labels & SDSs must always be available 24

25 Employees shall be informed of: the requirements of this section; any operations in their work area where hazardous chemicals are present; the location and availability of the written hazard communication program, including the required list of hazardous chemicals, and material safety data sheets required by this section. Informed Employees need to know what the standard means and where things are kept The method by which this is done is not specified Employees should be able to tell you where SDSs are kept how they can find/access SDSs where they can find/access a copy of the company s written Haz Com program where they can find/access the list of chemicals Requirements of the Section Applies to the HCS Operations in their work area Specific training is required; generalities are not sufficient Location/Availability Specific location were access can be found at ALL times Also includes info about how to access 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.); 25

26 Detection Any active or passive ways the employees can detect the presence or the release of a chemical Visual, odor are passive methods Alarms are active methods While not stated you may want to discuss odor & toxicity One does not necessarily mean the other Some chemicals are hazardous because they have no odor or are toxic before you can smell them 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; Training needs to address all of the types of hazards If there is no hazard in one of these specific categories there is no need to address it in the training 26

27 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; Cover any control measure used Engineering controls Enclosures Restricted areas Work practices PPE requirements Signage Emergency response actions should be addressed What employee are expected to do How to recognize they need to leave the area and call for help Other required OSHA training can supply more specific info or may overlap Respirators PPE HAZWOPER Emergency Action Plans Substance specific standards (lead, hexavalent chromium, formaldehyde, cadmium, etc.) The details of the hazard communication program developed by the employer, including an explanation of the labels 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. 27

28 This is where most of the big change sin your training program will occur Employee must be able to understand pictograms and what they mean hazard and precautionary statements In-plant labeling systems SDSs and where they can find hazard info on them Employees should be able to recognize the hazard(s) he/she is exposed to and. understand what he/she is supposed to do and. where they can get further information Don t try to make everyone a chemist or toxicology or safety professional Provide supplementary info such as glossaries for the technical info Focus on Sections 1 & 2-for unique or special hazards go over additional sections as necessary What are the educational levels of the employees? Do all employees speak, read and write English adequately? How much work experience do employees have? What kind of training methods have been used successfully with this same group of employees for other training Is there any documentation of previous HCS training? 28

29 General Information Stuff everyone needs to know Elements Understanding what the HCS is Understanding, accessing and using SDSs How to read labels General info on hazard categories Given to the subsets of employees affected Focus on most hazardous chemicals and exposures that represent the greatest risk Site specific training on single chemical May affect a small of group of employees Canned programs may not address these well Review SDSs and group hazards Identify what you want employees to do use controls use proper PPE follow proper work practices/handling store properly follow work rules (applicable to the chemicals) Know what to do in an emergency How to clean-up spills ID who to go to for more info 29

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31 Thank You! Kay Rowntree, CIH Industrial Hygiene Sciences, LLC 602 Fox Knoll Drive Waterford, WI