Globally Harmonized System of Classification and Labeling of Chemicals (GHS) New OSHA Requirements presented by: Safety Committee of the Houston Chapter, Associated General Contractors of America August 2013
Outline GHS what is it? OSHA Regulatory Status Hazard Communication Elements UN approach OSHA implementation GHS Label GHS SDS (formerly MSDS)
What is GHS? Global Harmonization System is a: Worldwide System for Chemical Hazard Communication Common and coherent approach to defining and classifying hazards for chemicals, and communicating such information on labels and safety data sheets. Provider of an underlying infrastructure for establishment of national, comprehensive chemical safety programs.
GHS History GHS, an international United Nations recommendation was: Initiated in 1992 Agreed upon in 2002 Published in 2003 Updated biannually and adopted into regional regulations. OSHA adoption in 2012 was consistent with the 3 rd revision of GHS
Major Changes to the Hazard Communication System Hazard classification: Specific criteria for classification of health and physical hazards, as well as classification of mixtures is provided. Lables: 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: A specified 16-section format will now be required for all products.
Employer Responsibilities Information & Training: Employers are required to train workers by December 1, 2013, on the new label elements and safety data sheets format to facilitate recognition and understanding. Hazard Communication System: Employers are required to evaluate chemicals used in the workplace and to maintain a written hazard communication system including safety data sheets for all products.
GHS Elements Classification Criteria Health Hazards Environmental Hazards Physical Hazards Mixtures Hazard Communication Labels Safety Data Sheets GHS is a standardized system for identifying chemicals throughout the world.
OSHA alignment of Hazard Communication Standard (HCS) with GHS Scope and application are basically the same! Essential components include: Evaluation of chemicals Written hazard communication requirement, i.e. SDS and labels Employee training Trade secret provision remains unchanged.
Standardized Hazard Communication Elements included in GHS: 1. Classification 2. Pictogram(s) 3. Signal Word 4. Hazard Statement(s) 5. Precautionary Statement(s) Note: Elements 1 4 should not be subject to variation and should appear on GHS label as described in the Purple Book for each hazard class. (BUT, in HazCom 2012, OSHA has included the Precautionary Statements as required text.)
1. Classification Determination is made of a hazard s: Nature and Severity Full range of scientific data is used in classifying. No testing is required. Classifications include: Physical Hazards Health Hazards Environmental Hazards
Physical Hazards Classification is based on the United Nations recommendations for Transport of Dangerous Goods: Explosive Flammable gases (includes chemically unstable), liquids, solids Aerosol (including flammable) Oxidizing liquid, solid, gases Self-Reactive Pyrophoric liquids, solids Self-Heating Organic Peroxide Corrosive to Metals Gases Under Pressure Water-Activated Flammable Gas
Health Hazards Acute Toxicity Skin Corrosion/Irritation Serious Eye Damage or Eye Irritation Respiratory or Skin Sensitization Aspiration Hazard Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Target Organ Systemic Toxicity Single and Repeated Dose
Environmental Hazards Hazardous to the Aquatic Environment Hazardous to the Ozone Layer
Combustible Dust OSHA additional requirements include: Covered separately from Hazard not Otherwise Classified Combustible dust is NOT specifically defined Guidance is to be taken from existing documents Directive for the National Emphasis Program National Fire Protection Association standards May apply to solids if process creates combustible dust MUST be addressed on label with statement: Warning. May form combustible dust concentrations in air.
Example: Acute Oral Toxicity ACUTE TOXICITY: ORAL Category 1 Category 2 Category 3 Category 4 Category 5 No pictogram Danger Fatal if swallowed Danger Fatal if swallowed Danger Toxic if swallowed Warning Harmful if swallowed Warning May be harmful if swallowed NOTE: Criteria for classification is acute LD50 or LC50. OSHA did not adopt Category 5 for acute toxicity. Notice that the category numbers go from low to high with lower numbers being more severe.
Example: Flammable Liquids FLAMMABLE LIQUIDS Category 1 Category 2 Category 3 Category 4 No pictogram Danger Extremely flammable liquid and vapor Danger Highly flammable liquid and vapor Warning Flammable liquid and vapor Warning Combustible liquid FP <=23C and BP <=35C FP <=23C and BP >35C FP >23C and <=60C FP >60C and <=93C Criteria for classification is flash point/boiling point. OSHA adopted all categories.
HMIS/NFPA vs. GHS Classification Numerical categorization HMIS/NFPA ratings 0 = Minimal 4 = Severe GHS ratings 1 = Severe 5* = Minimal * Individual hazard classes may have more or less than 5 hazard categories, but as numerical category goes from low to high, severity of hazard decreases.
2. Signal Words Danger or Warning Used to emphasize the hazard and to discriminate between the levels of hazards. Note: No use of the signal word Caution.
3. Hazard Statements A single harmonized hazard statement for each level of hazard with each hazard class. Example 1: Flammable liquids Category 1: Extremely flammable liquid and vapor Category 2: Highly flammable liquid and vapor Category 3: Flammable liquid and vapor Category 4: Combustible liquid Example 2: Skin Corrosion / Irritation Category 1: Causes severe skin burns and eye damage Category 2: Causes skin irritation Category 3: Causes mild skin irritation
4. Pictograms Pictograms are 9 symbols used to identify hazards. Images courtesy Wikimedia
These 5 are for physical hazards These 3 are for health hazards
Flame Pictogram What kinds of chemicals does this describe? Flammable Self-Reactive Pyrophoric Self-Heating Emits Flammable Gas Organic Peroxide
Flame Over Circle What kinds of chemicals does this describe? Oxidizer
Exclamation Mark What kinds of chemicals does this describe? Irritant Dermal Sensitizer Acute Toxicity (harmful) Narcotic Effect Respiratory Tract Irritation
Exploding Bomb What kinds of chemicals does this describe? Explosive Self-Reactive Organic Peroxide
Corrosion What kinds of chemicals does this describe? Corrosive
Gas Cylinder What kinds of chemicals does this describe? Gases under pressure
Health Hazard What kinds of chemicals does this describe? Carcinogen Reproductive Toxicity Mutagenicity Aspiration Toxicity Respiratory Sensitizer Target Organ Toxicity
Skull and Crossbones What kinds of chemicals does this describe? Acute Toxicity (severe)
Environmental pollutant OSHA doesn t enforce environmental regulations!* Part of GHS, but not 1910.1200 * Enforcement is by other federal and state environmental and wildlife agencies!
Match pictograms with their meanings Group Exercise Activity Flammables Narcotic Effects Oxidizers Self-heating Irritant Organic Peroxides Explosives Gases Under Pressure Carcinogen Dermal Sensitizer Acute Toxicity (harmful) Respiratory Tract Irritation Self-Reactives Corrosives Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity A B C D E F G H
5. Precautionary Statements Standardized but not fully harmonized in GHS but... OSHA has made standardized precautionary phrases mandatory unless manufacturer, importer or other responsible party can demonstrate that a precautionary statement is inappropriate to a specific substance or mixture
Precautionary Statements GHS label should include appropriate precautionary information, i.e. recommended measures for minimizing or preventing possible adverse effects from exposure to, or improper storage and/or handling of hazardous chemicals. Standardized precautionary statements are associated with specific hazard categories.
Precautionary Statements There are five types of precautionary statements. 1. General (Read label before use.) 2. Prevention (Keep container tightly closed.) 3. Response to accidental spills, emergencies and first aid (Get immediate medical attention.) 4. Storage (Protect from sunlight.) 5. Disposal (Refer to manufacturer for information on recycling.)
Changes from HazCom GHS labels are now standardized MSDS are now SDS
Sample OSHA label
Key Label Elements Product identifier Supplier identifier Name, address, telephone Signal words Pictograms Hazard statements Precautionary statements 5 types; includes 1 st aid information Note: supplier label may include additional information, but such information should provide further detail, but should not contradict standard elements or lower standards of protection.
GHS Label Product Identifier Signal Word Hazard Precautionary Statement(s) Supplier identifier Hazard Pictogram(s) Statement(s)
Example of a GHS label
Role of the SDS in the GHS SDS provides comprehensive information about a chemical substance or mixture. SDS is used primarily in the workplace. SDS is used by employers and workers as the source of information about hazards and to obtain advice on safety precautions. SDS relates to the protection of human health and the environment.
1. Identification SDS Format 16 headings 2. Hazard(s) identification 3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling and storage 8. Exposure control/personal protection
SDS Format 16 headings (cont.) 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 Note: Sections 12, 13, 14, and 15 are considered non-mandatory under OSHA proposal.
Reminder!
Questions? Contact for further information and assistance Doug Watson, C.S.H.O. Director of Safety Associated General Contractors of America Houston Chapter 3825 Dacoma, Houston, Texas 77092 Phone: 713-843-3720 Fax: 713-843-3777 doug.w@agchouston.org