Complying with the Revised OSHA HazCom Rule

HazCom is changing to GHS:

What does this mean for my company and employees?

Background Overview

Timeline

What is changing?

How to train employees

Additional Learning Resources

Agenda

Background OverviewWhy the changes?

How do the changes affect your company and your employees?

Original Hazard Communication Standard (1983)

◦ “Right to Know”

Revised Standard

◦ “Right to Understand”

Aligned with GHS

“Right to Understand”

Enhances worker comprehension of hazards

Reduces confusion in workplace

Facilitates safety training

Safer handling and use of chemicals

Quicker and more efficient access to information on safety data sheets (SDSs)

The Revision Helps Workers

US businesses save more than $475 million in productivity improvements

Fewer SDSs and label updates needed

Provides simpler HazCom training

Reduces trade barriers harmonized systems around the world

The Revision Helps Companies

Abbreviated: GHS

A common, coherent approach to define, classify and communicate hazards from chemicals

Agreed upon by the UN General Assembly

◦Modeled after existing systems in US, Canada, and Europe

Global Harmonization System for Classifying and Labeling Chemicals

Standardized system across countries

◦Creates systems in countries where none exist

Enhances global trade

◦ Fewer compliance burdens between different systems

Enhances protection of humans and the environment

Global Harmonization

What was hazardous before is STILL hazardous

GHS standardizes methods of classifying and communicating hazards

Classification Criteria

Communication Requirements

• Health and environmental hazards

• Physical hazards

• Labels

• Safety Data Sheets (SDS)

• Training

Global Harmonization

Acute Toxicity Carcinogenicity

Reproductive Toxicity Hazardous to Aquatic Environment*

Target Organ Toxicity (Single and Repeat Dose)

Serious Eye Damage/Irritation

Aspiration Toxicity Respiratory/Skin Sensitization

Skin Corrosion/Irritation Germ Cell Mutagenicity

Health and Environmental Hazards

*Exception: OSHA has no jurisdiction over aquatic toxicity (GHS does)

Explosives Self-Heating

Flammability Organic Peroxides

Oxidizers Corrosive to Metals

Self-Reactive Gases Under Pressure

Pyrophoric Water Activated Flammable Gases

Physical Hazards

GHS Implementation Timeline

Dec 1, 2013

• Train employees on new label elements and SDS format

• Affects employers

June 1, 2015

• Reclassified and prepared GHS-compliant SDSs

• Affects Chemical Manufacturers, Importers, Distributors, Employers

Dec 1, 2015

• All GHS Label Requirements must be implemented

• Affects Chemical Manufacturers, Importers, Distributors, Employers

June 1, 2016

• HazCom program must comply with GHS• Proper GHS

labels• Proper SDS• Additional

employee training to follow updated HazCom program

• Affects everyone

Comply with either existing Hazard Communication Standards (HCS) or the revised HCS, or both

It is okay if both standards for labels and SDSs are present in workplace (until 6/1/2016)

Between Now and 2016

Revisions Did Not Change…

◦Who is covered by HCS

◦Ability to protect trade secrets on labels, in SDSs, etc.

◦What types of substances are covered

The Bottom Line:

◦Documents will look different.

◦ The chemicals are the same.

Some Clarification

The ChangesWhat exactly is different?

Biggest change

Only employers who manufacture products/by-products are involved

New Process

◦Specific criteria for each health & physical hazard

◦Detailed instructions for hazard evaluation and determinations

◦Hazard classes divided into hazard categories

Hazard Classification

Who is affected?

◦ Everyone

◦ Especially chemical manufacturers and importers

Harmonized Labels

◦ Signal Word

◦ Pictogram

◦ Hazard Statement

◦ Precautionary Statement

6 Months to update labels when new information becomes known

Label Changes

Used to indicate relative level of severity of hazard

Alerts reader to potential hazard on label

“Danger” = more severe hazard

“Warning” = less severe hazards

“Caution” = no longer used

Label Changes: Signal Words

Graphic:

◦ White Background

◦ Red Square Frame

◦ Black Symbol

Conveys specific information about hazards of chemical

9 under GHS, only 8 required under OSHA HCS

Label Changes: Pictogram

Assigned to hazard class and category

Describes the nature of the hazard(s) of chemical (including degree of hazard, if appropriate)

Example:

◦ “Fire or protection hazard”

◦ “Fatal if inhaled”

Label Changes: Hazard Statement

Describes measures to be taken to minimize/prevent adverse effects that result from exposure to hazardous chemical, improper storage, etc.

Label Changes: Precautionary Statement

Type Example Statements

Prevention Do not spray on open flame or other ignition source.

Response Wash contaminated clothing before reuse.

Storage Protect from sunlight. Store in a well ventilated place.

Key Label Elements:

Product IdentifierSupplier IdentifierChemical IdentityHazard Pictograms*Signal Words*Hazard Statements*Precautionary Information

*Harmonized

Product Identifier & Chemical Identity

Supplier Identifier

(Harmonized) Hazard Pictograms

(Harmonized) Signal Words

(Harmonized) Hazard Statements

PrecautionaryInformation

MSDS

• Content Requirements• No Format

Requirements• Difficult to use during

training

SDS

• Content Requirements (Order Counts!)

• Format Requirements• Most critical

information shown first

Switching from MSDS to SDS

Training EmployeesWhat do employees need to know by June 1, 2013?

Training should include:

◦How to read labels and SDSs

◦How to respond safely to chemical hazards

Major changes are just revised elements of HCS

Ongoing training continue as usual

What to Cover in Training

Train employees BEFORE the labels appear

Make sure employees understand the labels

Training for Label Changes

Additional ResourcesWhere to learn more about the OSHA HazCom Revisions

“The Purple Book” published by the UN (also available on OSHA website)

OSHA Quick Cards for SDSs, Labels, and Pictograms

Learning Resources

OSHA’s “Hazard Communication” Webpage

◦Highlights and key information about HazCom, according to OSHA and the United States Dept. of Labor

Facts on Aligning the Hazard Communication Standard to the GHS

◦Published by OSHA

◦ FAQ about the changes

Get more information

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