HAZCOM 2012 RIGHT-TO-UNDERSTAND Helping you comply with 29 CFR 1910.1200
INTRODUCTION
REVISED HAZARD COMMUNICATION STANDARD 29 CFR 1910.1200 First major technical revision in 29 years HazCom is more than just OSHA Department of Transportation Consumer Product Safety Commission Environmental Protection Agency
WHAT IS GHS? GHS = Globally Harmonized System of Classification and Labeling of Chemicals Common & coherent approach to: Classifying and defining & communicating hazards Provides consistency/harmonization to labels and safety data sheets GHS is NOT a regulation, standard, or mandate but rather an approach
OSHA ALIGNMENT WITH GHS Compliance Enforcement Phased in Employees trained on label/sds by Dec. 1, 2013 Manufacturers & Distributers complete reclassification and produce update SDSs and labels by June 1, 2015 Distributers may ship inventory with old labels/sdss until Dec. 1, 2015 Full employer compliance expected by June 1, 2016 Transitional period can comply with old or new HCS/HazCom 2012
WHO IS RESPONSIBLE FOR WHAT? Employers who Use chemicals Are responsible for the following as part of a compliant HazCom program: 1. Written Hazard Communication Plan/Program 2. Written chemical inventory 3. Ensuring proper use of labels and warnings 4. Maintaining SDSs and providing Right-to-Know access to employees 5. Providing employee training
CHANGES
TWO MOST PREVALENT CHANGES Hazard Classification Criteria Health & Environmental hazards Physical hazards Mixtures Hazard Communication Labels Safety Data Sheets (SDSs) Training OSHA refers to revised standard as HazCom 2012
LABELS
WORKPLACE LABELING Employers may continue to use current workplace specific labeling systems If they contain required information Are consistent with new classifications Labels on incoming containers Must not be removed or defaced unless immediately replaced Workplace labels Must be prominently displayed In English Other languages permitted (additionally)
6 ELEMENTS OF LABELS Product/Chemical Identifier Supplier Identifier Hazard Pictogram(s) Signal Word Hazard Statement(s) Precautionary Information
LABELS PRODUCT IDENTIFIER CODE Product Name SAMPLE LABEL SUPPLIER IDENTIFICATION Company Name Street Address City State Postal Code Country Emergency Phone Number PRECAUTIONARY STATEMENTS Keep container tightly closed. Store in cool, well ventilated place that is locked. Keep away from heat/sparks/open flame. No smoking. Only use non-sparking tools. Use explosion-proof electrical equipment. Take precautionary measure against static discharge. Ground and bond container and receiving equipment. Do not breathe vapors. Wear Protective gloves. Do not eat, drink or smoke when using this product. Wash hands thoroughly after handling. Dispose of in accordance with local, regional, national, international regulations as specified. In Case of Fire: use dry chemical (BC) or Carbon dioxide (CO 2 ) fire extinguisher to extinguish. First Aid If exposed call Poison Center. If on skin (on hair): Take off immediately any contaminated clothing. Rinse skin with water. HAZARD PICTOGRAMS SIGNAL WORD Danger HAZARD STATEMENT Highly flammable liquid and vapor. May cause liver and kidney damage. SUPPLEMENTAL INFORMATION Directions for use Product/Chemical Identifier Supplier Identifier Hazard Pictogram(s) Signal Word Hazard Statement(s) Precautionary Information
LABEL PICTOGRAMS Skull & Crossbones Acute Toxicity (Fatal or toxic) Flame Exclamation Mark Skin & Eye Irritant Dermal Sensitizer Acute Toxicity (harmful) Transient Target Organ Effects Harmful to Ozone Layer (not mandatory) Flammable Self Reactive Pyrophoric Self-Heating Emits Flammable Gas Organic Peroxides
LABEL PICTOGRAMS Exploding Bomb Health Hazard Carcinogenicity Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity Aspiration Toxicity Gas Cylinder Explosives Self Reactive Organic Peroxide Gases Under Pressure
LABEL PICTOGRAMS Flame over Circle Oxidizers Corrosion Environment (Not Mandatory) Skin Corrosion Corrosive to Metals Serious Damage to Eye Environmental Toxicity
SAFETY DATA SHEETS (SDS)
SDS SAFETY DATA SHEET 1. Identification 2. Hazard(s) Identification 3. Composition/Ingredient Information 4. First-Aid Measures 5. Fire-Fighting Measures 6. Accidental Release Measures 7. Handling and Storage 8. Exposure Control / Personal Protection 9. Physical & Chemical Properties 10. Stability & Reactivity 11. Toxicological Information 12. Ecological Information 13. Disposal Considerations 14. Transport Information 15. Regulatory Information 16. Other Information
EMPLOYEE TRAINING
EMPLOYEE TRAINING 1910.1200(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 is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemicalspecific information must always be available through label and safety data sheets.
EMPLOYEE TRAINING 1910.1200(h)(2) Employees shall be informed of: The requirements of this section; Any operations in their work area where hazardous chemicals are present; and, The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and safety data sheets required by this section
EMPLOYEE TRAINING 1910.1200(h)(3) Employee training shall include at least: Methods and observations that may be used to detect the presence or release of hazardous chemical in the work area (such as monitoring, visual appearance or odor of hazardous chemicals when being released, etc.) 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;
EMPLOYEE TRAINING 1910.1200(h)(3) Employee training shall include at least: 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,
EMPLOYEE TRAINING 1910.1200(h)(3) Employee training shall include at least: 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
FAQS Q. Will the NFPA and/or HMIS diamonds still be applicable? A. There is nothing in HazCom 2012 that prevents their use. However, NFPA and HMIS are voluntary systems and their use has never been part of the mandatory requirements of the HCS.
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