Hazard Communication 29 CFR 1910.1200 Effective March 1, 2014
Subpart Z - Toxic & Hazardous Substances (1910.1000-1450) Hazard Communication - Written program 1200(e)(1) Hazard Communication - Information & training 1270 Standard: 1910. 1200(h)(1) 1200(g)(1) 1200(g)(8) Hazard Communication MSDS for each chemical used 282 374 825 Hazard Communication MSDSs readily accessible Hazard Communication Label identification 1200(f)(5)(i) 254 Most Frequently Cited Serious FY 2011
Global Harmonized System Overview GHS Purple Book Elements Harmonized criteria for classifying substances and mixtures according to their health, environmental and physical hazards Harmonized hazard communication elements, including requirements for labeling and safety data sheets.
GHS Overview Justification Label requirements differ, requiring multiple labels for the same product Hazard definitions are not consistent Toxicity, Flammability Over 100 diverse hazard communication regulations for manufacturer s products globally. Regulatory compliance is complex and costly Barrier to international trade in chemicals
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Hazardous Communication Standard 1983: OSHA s Mandates the Hazard Communication Standard - 1910.1200. 2015: Major Overhaul to the Standard!
GHS Dates Federal Effective Completion Dates: December 1, 2013: Employers must train employees on the new label elements and SDS format.
GHS Dates Federal Effective Completion Dates: June 1, 2015* Chemical manufacturers, importers, distributors and employers must comply with all modified provisions of this final rule, except Distributors may ship products labeled by manufacturers under the old system until December 1, 2015. (* This date coincides with the European Union implementation date for classification of mixtures)
GHS Dates Federal Effective Completion Dates: June 1, 2016: Employer s must update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Transition Period Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both for all chemical manufacturers, importers, distributors and employers.
Purpose 29 CFR 1910.1200(a)
OSHA Hazard Communication Standard Major changes to the Hazard Communication Standards Changed hazard determination to hazard classification Changed MSDS to SDS Changed definitions to comply with GHS Mandatory Training requirements Appendix A-D A- Health Hazard Criteria B- Physical Criteria C- Label Elements D- Safety Data Sheet (SDS)
OSHA Hazard Communication Standard Major changes to the Hazard Communication Standards Labels for shipped containers must have GHS information Workplace labels may be GHS labels, or other labels that identify the material and hazard Safety Data Sheets with 16 sections May include guidance for transportation information and environmental hazards
OSHA Hazard Communication Standard Major changes to the Hazard Communication Standards (cont.) Other OSHA standards are changed where applicable New wording on warning signs for asbestos and other health hazards Changes to standards for HAZWOPER, Combustible and Flammable Liquids, Welding Cutting and Brazing, etc.
Written Hazard Communication Program 29 CFR 1910.1200(e)
Written Hazard Communication Program 29 CFR 1910.1200(e)(1) Employers shall develop, implement, and maintain at each workplace Labels and Other Forms of Warning procedures Safety Data Sheet (SDS) procedures Employee Information and Training procedures
Written Hazard Communication Program 29 CFR 1910.1200(e)(1) continued List of the Hazardous Chemicals using Product Identifier Methods used to inform employees of Hazards of Non-routine Tasks Hazards associated with chemicals contained in unlabeled piping in their work areas
Written Hazard Communication Program 29 CFR 1910.1200(e)(2) Multi-Employer Workplaces Procedures for other employers employees to have on-site access and information regarding Labels and Other Forms of Warning procedures Safety Data Sheet (SDS) procedures Employee Information and Training procedures
Written Hazard Communication Program 29 CFR 1910.1200(e)(2) continued Multi-Employer Workplaces List of the Hazardous Chemicals using Product Identifier Methods used to inform employees of Hazards of Non-routine Tasks Hazards associated with chemicals contained in unlabeled piping in their work areas
Employee Information & Training 29 CFR 1910.1200(h)
Employee Information & Training 29 CFR 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 Whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area
Employee Information & Training 29 CFR 1910.1200(h)(2) i. Hazard Communication Program requirements ii. Any operations in their work area where hazardous chemicals are present iii. Location and Availability of Written Hazard Communication Program List(s) of the Hazardous Chemicals Safety Data Sheets (SDSs)
Employee Information & Training 29 CFR 1910.1200(h)(3) i. Methods & Observations used to detect the presence or release of a hazardous chemical in the work area ii. Physical Health hazards iii. Measures employees can take to protect themselves from chemical hazards
Employee Information & Training 29 CFR 1910.1200(h)(3) continued iv. Details of the Written Hazard Communication Program Labels and Other Forms of Warning procedures Safety Data Sheet (SDS) procedures, including the order of information Training
GHS Required Training Physical Hazards ( Appendix A) 16 categories Health Hazards (Appendix B) 10 categories Labeling (Appendix C) Safety Data Sheets (SDS) (Appendix D)
GHS Hazard Classification Health Hazards (10) Acute Toxicity Skin Corrosion/Irritation Serous 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
GHS - Hazard Classification Physical Hazards (16) 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
Labeling
GHS - Labels Labels (Appendix C) Symbols (hazard pictograms) with red border Examples:
GHS - Labels Signal Words Danger or Warning Hazard Statements Example: Toxic if swallowed Other Precautions, identification, supplier, supplemental
GHS - Labels GHS - Label Elements for Flammable Liquids
GHS - Label example
GHS Safety Data Sheets Safety Data Sheet (SDS) (Appendix C) 16 headings Similar to ISO, EU, and ANSI MSDS/SDS requirements
ANSI MSDS format (GHS) ANSI Z400.1-2004 1. Product and Company Identification 2. Hazard 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 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
Safety Data Sheets (SDS) 29 CFR 1910.1200(g)(10) SDS may be in any form Operating Procedures Designed to cover groups of chemicals in a process, rather than individual chemicals Hard Copy On Line (Computer Database) Must be readily accessible during each work shift to employees in their work areas