Revised Hazard Communication Standard (GHS) Triumvirate Environmental
Why is GHS Needed? No country has the ability to identify and specifically regulate every hazardous chemical product For example, in the United States, there are an estimated 945,000 such products Adoption of requirements for information to accompany the product helps address protection needs
Why is GHS Needed? (cont.) Countries with systems that address these needs have adopted different requirements for hazard definitions as well as information to be included on a label or material safety data sheet. This impacts both protection and trade. An estimated 41 million employees are potentially exposed to hazards chemicals
Why Does OSHA want this? OSHA's Hazard Communication Standard (HCS) has performance-oriented requirements for labels and safety data sheets Hazard communication is often inconsistent as a result Users of labels and safety data sheets would prefer a standardized approach Adoption of the GHS would address this domestic concern
Major Revisions to the HCS Hazard Classification Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures and chemicals Labels Chemical manufactures 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.
Major Revisions to the HCS Safety Data Sheets Will now be required to be in the 16 part format Information and Training All employers are required to train workers on the new labels, elements and safety data sheets format Refined definitions of Flammable Liquids and Toxicity
What is the primary benefit? The primary benefit of the revised standard is to increase the quality and consistency of information provided to workers, employers and chemical users by adopting a standardized approach to hazard classification, labels and safety data. Estimated to prevent 43 fatalities and 521 injuries and illness per year.
What are the primary benefits? OSHA estimates that the monetized health and safety benefits of the final rule are $250 million annually and that the annualized cost reductions and productivity gains are $507 million annually. The revised standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards
What are some key terms in the Revised Standard? SDS - Safety Data Sheet. SDS is the term used by GHS for Material Safety Data Sheet (MSDS). Hazard Category These categories compare hazard severity within a hazard class Classification - is the term used to describe the different hazards.
What are some key terms in the GHS Vocabulary? Hazard Statement - For each category of a class, a standardized statement is used to describe the hazard. The hazard statement would appear both on the label and on the SDS. Signal word - There are two signal words in the GHS system - Danger and Warning. There are categories where no signal word is used.
What are some key terms in the GHS Vocabulary? Pictogram - Pictogram refers to the GHS symbol on the label and SDS. Not all categories have a symbol associated with them.
New Flammable Liquid OSHA deleted the term Combustible Liquid Flammable liquid means any liquid having a flashpoint at or below 199.4 [deg]f (93 [deg]c).
New Flammable Liquid Flammable liquids are divided into four categories as follows: Category 1 shall include liquids having flashpoints below 73.4F and boiling point at or below 95F. Category 2 shall include liquids having flashpoints below 73.4F and a boiling point above 95F Category 3 shall include liquids having flashpoints at or above 73.4 F and at or below 140F. Category 4 shall include liquids having flashpoints above 140F and at or below 199.4F
Flammable Liquid Storage Container Type Category 1 Category 2 Category 3 Category 4 Glass or Approved Plastic Metal (other than DOT drums) 1 pint 1 quart 1 gallon 1 gallon 1 gallon 5 gallons 5 gallons 5 gallons Safety Cans 2 gallons 5 gallons 5 gallons 5 gallons Metal Drums (DOT approved) Approved Portable Tanks 60 gallons 60 gallons 60 gallons 60 gallons 660 gallons 660 gallons 660 gallons 660 gallons
What are the classes within the Health hazard group? Acute toxicity Skin corrosion/irritation Serious eye damage/eye irritation Respiratory or skin sensitization Germ cell mutagenicity Aspiration hazard Carcinogenicity Reproductive toxicity Specific target organ toxicity - single exposure Specific target organ toxicity - repeated exposure, and
What are the classes within the Physical hazard group? Explosives Flammable gases/aerosols Oxidizing gases Gases under pressure Flammable liquids/solids Self-reactive substances and mixtures Corrosive to metals Pyrophoric liquids/solids Self-heating substances and mixtures Substances and mixtures which, in contact with water, emit flammable gases Oxidizing liquids/solids Organic peroxides
Example Labels
Flammable Liquid Flammables Pyrophorics Self-Heating Emits Flammable Gas Self-Reactives Organic Peroxides
Exploding Bomb Explosives Self-Reactives Organic Peroxides
Corrosive Skin Corrosion/Burns Eye Damage Corrosive to Metals
Irritant Irritant (skin and eye) Skin Sensitizer Acute Toxicity Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (Non-Mandatory)
Flame Over Circle Oxidizers
Gas Cylinders Gases Under Pressure
Skull and Crossbones Acute Toxicity (fatal or toxic)
Health Hazard Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity
Environment (Non-Mandatory) AQUATIC TOXICITY
Signal Words
Signal Words The final rules requires the use of only two signal words for labels»danger»warning Danger is used for the more severe hazards Warning denotes less of a hazard
Regulated Chemicals Signal Words OSHA has revised the regulated signage for substance specific health standard materials These include, but are not limited to the following materials: Asbestos Lead Cadmium Ethylene Oxide Formaldehyde Benzene
Safety Data Sheets
Safety Data Sheets The safety data sheet should provide comprehensive information about the chemical that allows employers and workers to obtain concise, relevant and accurate information that can be put in perspective with regard to the hazards, uses and risk management of the chemical product in the workplace.
Safety Data Sheets The SDS must contain 16 sections. While there were some differences in existing industry recommendations, and requirements of countries, there was widespread agreement on a 16 section SDS that includes the following headings in the order specified:
Safety Data Sheets Identification Hazard(s) identification Composition/ information on ingredients First-aid measures Fire-fighting measures Accidental Release Measures Handling and storage Exposure control/ personal protection Physical and chemical properties Stability and reactivity Toxicological information Ecological information Disposal considerations Transport information Regulatory information Other information.
Hazard and Precautionary Statements
Hazard and Precautionary Statements Hazard Statements describe the hazards associated with a chemical Precautionary Statements describe recommended measures that should be taken to protect against hazardous exposures, or improper storage or handling of a chemical
Hazard and Precautionary Statements OSHA has stated that standardizing the requirements for hazard and precautionary statements will provide a degree of consistency that is lacking among the current chemical labels.
Example New Posting for Formaldehyde DANGER Formaldehyde Irritant and Potential Cancer Hazard Authorized Personnel Only DANGER Formaldehyde May Cause Cancer Causes Skin, Eye, and Respiratory Irritation Authorized Personnel Only
Example GHS Inner Container Label (e.g., bottle inside a shipping box) ToxiFlam (Contains: XYZ) Danger! Toxic If Swallowed, Flammable Liquid and Vapor Do 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, CO 2, or "alcohol" foam. See Material Safety Data Sheet for further details regarding safe use of this product. MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999
Example GHS Outer Container Label (55 gallon/200 liter drum) Flammable liquids, toxic, n.o.s. Danger! Toxic If Swallowed Flammable Liquid and Vapor (contains XYZ) UN 1992 Do 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, CO 2, or "alcohol" foam. See Material Safety Data Sheet for further details regarding safe use of this product. MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999
Training Requirements
Training Requirements The new standard does not impose employee training requirements; however, OSHA believes that additional training will be necessary to ensure that employees understand the new elements, particularly on the new pictograms. Therefore, modified training requirements have been included in the final rule in order to address the new label elements and SDS format required under this revised standard.
Training Requirements 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.
Training Requirements OSHA estimates that employee training will take up to: One Hour per production employee in most industries Thirty minutes in occupations exposed to a few hazardous chemicals and types of hazards Ten minutes per employee in some occupations where GHS-type pictograms are already in use
Important Dates to Remember
Important Dates to Remember December 1, 2013. Employers must train employees on the new label elements contained in the standard and the new format for Safety Data Sheets. June 1, 2015. Chemical manufacturers, importers, distributors and employers must comply with all modified provisions of the revised Hazard Communication Standard except that distributors of chemicals covered by the standard are allowed to ship products, labeled by manufacturers under the old system, until December 1, 2015.
Important Dates to Remember June 1, 2016. Employers are required to update alternative workplace labeling and their written Hazard Communication Program to bring them into full compliance with the revised standard and to provide additional training for newly identified physical or health hazards.
Other OSHA Regulations Affected Laboratory Standard Need to update the definitions Hazardous Waste Operations and Emergency Response Need to update definitions Need to train on the new labels, physical and health hazards Spray finishing New flammable liquid requirements Welding, Cutting and Brazing Changes to the Substance Specific Standards (lableling)
Other U.S. Agencies Effected The Department of Transportation (DOT), Environmental Protection Agency (EPA), and the Consumer Product Safety Commission (CPSC) were actively involved in developing the GHS. DOT has already modified their requirements for classification and labeling to make it consistent with international UN transport requirements and the GHS.
Questions??
Thank you Rick Foote Consulting Services Manager, Industrial 617-686-6184 rfoote@triumvirate.com