osha ghs what’s needed to be compliant? · and importers are required to: • obtain or develop a...

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OSHA GHSWhat’s needed to be

compliant?November 13, 2013

Sponsored by:

Webinar Details• Hosts

• Cheryl Skjolaas

UWEX Madison/Extension Center for Agricultural Safety and Health

• Mark Hagedorn

UWEX Eau Claire County Agricultural Agent and Dairy Team Co-Leader

• Audio - Please mute your phone

• Discussion Tools

• Questions

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Bios & Contacts• Mary Bauer – Eau Claire Area OSHA Office

Compliance Assistance Specialist (CAS)1310 West Clairemont AveEau Claire, WI [email protected]

• Compliance Officer for 20 Years• CAS for 8 Years• All in Eau Claire Area Office• CIH: Certified Industrial Hygienist• CSP: Certified Safety Professional

• Explaining GHS− What is not changing− What is changing

—Safety Data Sheets—Labeling

• Suggestions for compliance

Webinar Objectives

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1983Hazard Communication

StandardEvery employee has a “Right to Know” about chemicals and hazardous substances

Chemical Manufacturers

Responsibility for:

• Evaluating chemicals produced or imported

• Labeling and safety data sheets

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Why AlignHCS with GHS?

GOAL: A common, coherent approach to classifying and communicating chemical hazards

• Harmonized definition of hazards• Specific labeling criteria• Standardized format for safety data

sheets (SDS)

GHS Benefits• Improve quality and information

and consistency of information • Reduce confusion/increase comprehension of

hazards

• Improve downstream risk management

• Facilitate training

• Address literacy levels a diverse workforce

• Facilitation of international chemical trade

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Hazard Communication Standard (HazCom)

Created to protect workers:

• provide information about chemical hazards and hazardous substances

• how to protect against those hazards

What makes a chemical

hazardous?

• Health hazards• Physical hazards

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Health Hazards

Is it a: • Carcinogen• Corrosive• Highly Toxic• Irritant• Sensitizer• Toxic• Target Organ Effects

?

Health Hazards

• Cause acute health problems -corrosives that can burn eyes or skin

• Cause chronic health problems - toxic chemicals that can cause long-term illnesses, such as cancer

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Physical Hazards

• Flammable/Combustible• Compressed Gas• Explosive• Organic Peroxide• Oxidizer• Pyrophoric• Unstable• Water Reactive

What Hasn’t Changed

Chemical manufacturers and importers are required to:

• Obtain or develop a MSDS for each hazardous chemical produced or imported

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Ensuring that customers are provided a copy of MSDSs or SDSs.

Distributors and suppliers:


• Develop a written program describing how the standard elements are implemented

• Maintain a list of all hazardous chemicals

• Obtain and make MSDS’s or SDSs available to employees

Employers are required to:

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• Provide employees with HazComtraining

• How to recognize, understand and use labels and MSDS’s (SDS)

• Using safe procedures when working with hazardous substances

• Address non-routine tasks

Employers are required to:


• Read labels and MSDS’s (SDS)

• Follow label and MSDS (SDS) instructions and warnings

• Know about chemicals they will use BEFORE attempting to use them

Employees are required to:

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What Changed?

• Updates to HazCom became final on May 26, 2012 HazCom 2012

• The majority of the changes involved adopting the Globally Harmonized Standard for Classification of Chemicals or GHS

• Most significant changes related to data sheets and labeling

HazCom 2012

Safety Data Sheet or SDS will replace or update Material Safety Data Sheet (MSDS)

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Safety Data Sheet

• Under HazCom 2012, SDS have been expanded from 9 to 16 sections

• Manufacturers must now follow a specific order or format

Consistency

Safety Data Sheet• Sections 12-15 will not be mandatory

by OSHA - address information outside OSHA’s jurisdiction

• Appendix D titled “Safety Data Sheets” has been added to the standard and details what is to be included in each section

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Safety Data Sheet Format 1. Identification of the substance or mixture and of the supplier2. Hazard identification3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures6. Accidental release measures7. Handling and storage8. Exposure controls/personal protection9. Physical and chemical properties10. Stability and reactivity11. Toxicological information12. Ecological information (non-mandatory)13. Disposal considerations (non-mandatory)14. Transport information (non-mandatory)15. Regulatory information (non-mandatory)16. Other information, including date of preparation or last

revision

Foot Baths• Effectiveness: Multi-Purpose

• Health Hazards

− Pre-mixed

− Powder form

• Cost Effective• Formaldehyde on List of

Human Carcinogens

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Sample SDS

Sheet

Sample SDS

Sheet

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LabelingUnder HazCom 2012, labels are required to include:

– Product identifier (name)– Name, address and telephone number

of the chemical manufacturer, importer or other responsible party.

– Signal word– Hazard statements– Precautionary statements and….– Pictograms

Labeling Example

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Pictograms

Section 3 Hazard Identification

• Hazard Description– Toxic– Highly flammable

• Risk and Safety phrases– R codes– S codes

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Risk Hazards

Sample Risk Phrases

Risk Phrase Risk Category• Flammable• Highly flammable• Extremely

flammable

• Very toxic in contact with skin

• Very toxic if swallowed

• Category 3• Category 2• Category 1

• Category 2

• Category 2

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Combined Risk Phrases

• Very toxic by inhalation and in contact with skin

• Very toxic by inhalation and if swallowed

• Very toxic by inhalation, in contact with skin and if swallowed

• Very toxic in contact with skin and if swallowed

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(j) Effective DatesEffective Completion Date

Requirement's) Who

December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format.

Employers

June 1, 2015*December 1, 2015

Compliance with all modified provisions of this final rule, except:The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label

Chemical manufacturers, importers, distributors and employers

June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

Employers

Transition Period to the effective completion dates noted above

May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both

Chemical manufacturers, importers, distributors, and employers

Your HazCom 2012 Program

• Conduct a thorough review of hazardous chemicals and substances used or stored at your facility

• Develop a list as it is required

Between now and June 1, 2016 do the following:

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• On list have separate columns for MSDS and SDS

• Go through entire list and contact the manufacturer by phone or website to obtain a SDS

– If the SDS, is available get it!

– If not, at least have the MSDS

• Place a check in the SDS column as SDS forms are obtained


• Every 3 to 6 months go back to your list and attempt to obtain more SDS’s until you get them all.

• Phase-in process -you will not be successful obtaining SDS’s right away

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• Update labeling in written program

• Labels for portable containers in the workplace must have either:

– The same information as the manufacturer label with the exception of the manufacturer’s address

or…

– Product identifier and words, pictures, symbols or combination which provide employees with specific information regarding the health and physical hazards of the chemical

Tracking of Chemical Inventory

Non-Mandatory/Optional

ChemicalName

MSDSYes or No

SDSYes or No

SDS Requested?Need by 6/1/2016

Label GHS Compliant?

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NFPA and HMIS Labeling Systems

These 2 labeling systems have been acceptable to OSHA for labeling portable containers for years

NFPA and HMIS Labeling Systems

Problem:Very general hazard information about the chemical

Result: NFPA and HMIS labeling systems will no longer comply with HazCom 2012 labeling requirements

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NFPA Diamond

4= Deadly Hazard3= Severe Hazard2= Moderate Hazard1= Slight Hazard0= No Hazard

Other Warning Systems vs GHS

• NFPA uses 0-4 scales with 4 being most hazardous

• HMIS uses 0-4 scales with 4 being most hazardous

• GHS uses 1- 4 scales with 1 being the most hazardous

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Health Hazards ClassificationsHazard Class Hazard Category

Acute Toxicity 1 2 3 4

Skin Corrosion/Irritation 1A 1B 1C 2

Serious Eye Damage/ Eye Irritation 1 2A 2B

Respiratory or Skin Sensitization 1

Germ Cell Mutagenicity 1A 1B 2

Carcinogenicity 1A 1B 2

Reproductive Toxicity 1A 1B 2 Lactation

STOT –Specific Target OrganToxicity - Single Exposure 1 2 3

STOT – Repeated Exposure1 2

Aspiration 1

Simple Asphyxiants Single Category

Physical HazardsHazard Class Hazard CategoryExplosives Unstable

ExplosivesDiv 1.1 Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6

Flammable Gases 1 2 Flammable Aerosols 1 2 Oxidizing Gases 1 Gases under Pressure Compressed Gases Liquefied Gases Refrigerated Liquefied Gases Dissolved Gases

1

Flammable Liquids 1 2 3 4 Self-Reactive Chemicals Type A Type B Type C Type D Type E Type F Type G Pyrophoric Liquids 1 Pyrophoric Solid 1 Pyrophoric Gases Single

category

Self-heating Chemicals 1 2 Chemicals, which in contact with water, emit flammable gases

1 2 3

Oxidizing Liquids 1 2 3 Oxidizing Solids 1 2 3 Organic Peroxides Type A Type B Type C Type D Type E Type F Type G Corrosive to Metals 1 Combustible Dusts Single

Category

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FLAMMABLE LIQUIDS(Classified in Accordance with Appendix B.6)

PictogramFlame

Hazard category

Signalword

Hazard statement

1 Danger Extremely flammable liquid and vapor

2 Danger Highly flammable liquid and vapor

3 Warning Flammable liquid and vapor

PictogramNo Pictogram

Hazardcategory

Signal word

Hazard statement

4 Warning Combustible liquid

Your HazCom 2012 Program - Labeling

• Continue using the NFPA or HMIS labels –compliant with current standard

• Look into HazCom 2012 compliant labeling systems for workplace containers and incorporate into your written program

Between now and June 2016 you need to…..

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Your HazCom 2012 Programm - Labeling

• HMIS label group is currently attempting to revise their system to be compliant

• NFPA ??• 3-year window to see what type of

workplace labeling systems are developed and decide which system to use

Your HazCom 2012 Program - Labeling

Secondary Containers:

The employer is not required to label portable containers when hazardous chemicals are transferred from labeled containers and are intended only for the immediate use of the employee who performs the transfer

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HazCom 2012 Summary• Develop a written program describing how the standard

elements are implemented

• Maintain a list of all hazardous chemicals.

• Obtain and make safety data sheets (SDS) available to employees

– SDS are the “new” MSDS

– SDS have 16 sections and a specific format for consistency of information

• Provide employees with training

• Address non-routine tasks.

HazCom 2012 SummaryLabeling on containers will now be required to have the following information:

• The product identifier (name)

• Signal word

• Hazard statements

• Pictograms

• Precautionary statements Name, address and telephone number of the chemical manufacturer, importer or other responsible party

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FAQ: English Only?

Question:• What languages do

the labels have to be written in?

Answer:• Labels….prominently

displayed, and in English (other languages may also be included if appropriate).

• The chemical manufacturer or importer preparing the safety data sheet shall ensure that it is in English (although the employer may maintain copies in other languages as well),

For More FAQ:

http://www.osha.gov/dsg/hazcom/index.html

OSHA Website: Haz Com

Page

http://www.osha.gov/dsg/hazcom/index.html

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Summary

• December 1, 2013: First Date for Employee Training

• Training Critical:

– In the language understood

• Documentation Important

Eau Claire

Madison Milwaukee

Appleton

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Wisconsin Compliance Assistance Specialists

Kelly Bubolz Leslie PtakU. S. Dept. of Labor - OSHA U. S. Dept. of Labor - OSHA1648 Tri Park Way 4802 E. BroadwayAppleton, WI 54914 Madison, WI 53716(920) 734-4521 (608) 441-5388

Mary Bauer Jim LutzU. S. Dept. Of Labor - OSHA U. S. Dept. of Labor - OSHA1310 W. Clairemont Ave 310 W. Wisconsin AveEau Claire, WI 54701 Milwaukee, WI 53203(715) 832-9019 (414) 297-3315

osha ghs what’s needed to be compliant? · and importers are required to: • obtain or develop a...

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