Update on the Implementation of the Globally Harmonized System of

Classification and Labeling of Chemicals (GHS) at the Hanford SiteRaja Atallah*, PhD, Mark Hermanson, and Pete Wells

Mission Support Alliance, Richland, WA

June 2015

GHS Introductory Video

Introduction

• OSHA Adopts GHS in March 2012

• OSHA Established an Implementation Timeline

• DOE Directed Mission Support Alliance (MSA) in June 2012 to Take the Lead for Hanford Implementation

• Hanford Inter-Contractor Work Group Established , June 2012

Effective 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

GHS Implementation Timeline

3-25-2012

12-1-2

013

6-1-

2015

12-1

-201

5

6-1-

2016

Implementation Process

• Training

• Hazard Container Labeling: Primary and Secondary

• Document Revisions: Chemical Management and HAZCOM Procedures

• Modified Data Bases

• Transition and Communication

Training Implementation at Hanford

• Worked with EFCOG on Developing Training

• Updated Hanford General Education Training (HGET), November 2012 (Video)

• Updated HAZCOM Section of the Hazardous Waste Operations and Emergency Response (HAZWOPER), Training, November 2012

• Developed Advanced GHS HAZCOM Training

• Updated the HAZCOM section for the Workers Basic HAZCOM Training

Hanford General Employee Training (HGET):

Hazardous Waste Operations and Emergency Response (HAZWOPER):

Basic HAZCOM Training

Site-Location Specific Training

Workers Training

Advanced GHS Training

• Provide in-depth training to professionals who will be advising workers or assisting with work planning

• Provide in-depth training to professionals who will be preparing and conducting GHS training to workers.

• Professionals attend the training

• Training duration four hours

Advanced GHS Training Course Outline

• Introduction to GHS

• Overview of the Revised HAZCOM Standard

• Summarize Criteria for Health, Physical and Environmental Hazard Classifications

• Discuss Elements of the GHS label and Safety Data Sheet

• Present Hanford Implementation of GHS: (Training, Labeling, Databases, Webpage, Document Revisions, Chemical Procurement Forms, Job Hazard Analysis)

• Discuss Changes Made or Anticipated by Other Organizations or Agencies

The Nature of Chemical Hazards

OSHA Defined & Listed Hazard Classes• Pyrophoric Gases• Combustible Dusts• Simple Asphyxiant• Hazards Not

Otherwise Classified

Globally Harmonized System (GHS)

GHS Poster

GHS Poster Example elements of the Standard

Health Hazards

Physical Hazards

GHS Poster Example elements of the Standard

OSHA Defined / Listed Hazards(Label Elements)

Hazard Class / Category Determination CriteriaOSHA - 29 CFR 1910.1200 Appendix A

Example Health Hazard: Acute Toxic (Oral, Dermal, Inhalation)

Hazard Class / Category Determination CriteriaUnited Nations GHS Standard (The Purple Book)

Example Health Hazard: Acute Toxic (Oral, Dermal, Inhalation)

Summary of Changes to HAZCOM Health Hazards

Summary of Changes to HAZCOM Health Hazards

Summary of Changes to HAZCOM Health Hazards

The GHS standard defines the label elements that must be placed on the primary (manufacturer’s) container. However, the GHS-HCS only established a general guideline for labeling the secondary (site repackaged) container. This guideline requires employers to use words, pictures, symbols, and other information to inform their employees on the physical and health hazards of the hazardous chemical.

Primary and Secondary GHS Labeling

GHS Manufacturer Label Elements Review

• Product Name/Identifier

• Pictogram(s)

• Signal Word

• Hazard Statements

• Precautionary Statements

• Supplementary Information

• Manufacturer Name and Emergency Contact

Workplace LabelingSecondary Container Labels

• Product Name/Identifier

• Pictogram

• Signal Word

• Hazard Statements

• Manufacturer Name

• Added Hanford GHS-SDS Number

• Removed Precautionary Statements

• Removed Manufacturer’s Emergency Contacts

• OSHA Requirements are Imprecise• Basic Content

• Hanford Workplace Labeling• Product & Manufacturer• Hanford Unique SDS Number• Color Coding• Signal Words and Pictograms• Hazard Statements• No Precautionary Statements• No NFPA 704 Hazard Ratings• The Value of Standardization• Possible Harsh Environments• EFCOG Best Practice

Radio Frequency Identification

Workplace LabelingSecondary Container Labels

NFPA-704 Hanford Hazard Container (HHC) Label

Flammability

Health Instability (Formerly Reactivity)

Specific Hazard:Oxidizer, (OX)

Water Reactive (W)

NFPA-704Degrees of Hazard 0-4

NFPA-704 (HHC) / GHS (HHC) Labels

Ammonium SulfamateJT Baker

Harmful if Swallowed

MakingSecondary Container Labels

None None

GHS (HHC) Label Variations

SDS and Secondary Label

The Best Practice on GHS compliant Hazard Label was awarded the 2015 EFCOG teamwork award for exceptional performance by a group of individuals who were instrumental in addressing a key EFCOG issue.

Mark Hermanson - MSAJeff Hieb - ATLMikhail Alnajjar - PNNLBruce Dickey - MSARaja Atallah - MSA

EFCOG Teamwork Award

Proposed Dates

Role Completed By

October 2014 Identify products that require secondary labels

(Facilities/CMSs)

January 2015 Worker training on new labels FEHIC Trainers

June 2015 Obtain SDSs for these products Facilities

June 2015 Review GHS-SDSs and provide labeling information

(IHs/HAZCOM-SME)

October 2015 Prepare labels at sign shop (Facilities/CMSs)

January 2016 Replace labels (Facilities/CMSs)

Hanford Implementation Plan - Labels

SDS-MSDS and CITS Databases

Chemical Inventory Tracking System

• Used by all Hanford Contractors for Inventory Tracking/Reporting• Product by Manufacturer• Identifies Constituents• NFPA Hazard Ratings• GHS Hazard Class, Category, and Statements

Safety Data Sheet – Material Safety Data Sheet

• Used by all Hanford Contractors for Basic Haz Com• All Current and Past SDS-MSDS Documents• Assigns a Hanford Unique SDS-MSDS Document Number• Distinguishes Between SDS and MSDS Formats• Product Name, Synonyms, Manufacturer, and Catalogue ID• SDS-MSDS Date

DATA

SDS – MSDS Database

Labeling MSDS and SDS Documents

CITS Database GHS Hazard Information Report

Required Changes to Procedures, Forms, Databases

HCS 1992 HCS –GHS 2012MSDS SDS

Flammable Liquids New criteria for flash points and boiling points

Combustible liquid Removed

Health Hazard Definitions (e.g. Sensitizer, Irritant , highly toxic)

Changed

Physical Hazard Definitions (e.g. Gases, )

Changed

Chemical Definition Changed to Substance

Examples of Procedures, Forms, and Databases

Document Examples

Procedures/Required Documentation/Plans/Guides

• Hazard Communication• Chemical Management• Occupational Carcinogen• Chemical Hygiene Plans• Hazard Analysis Documents

Databases • CITS• SDS/MSDS

Forms • MSA-CPS• MSA-CIW

Hanford’s GHS Web Page

Implementation Plan

Planned Action Implementation Process (Requirement)

Implementation Date and Status

Establishing Hanford GHS Working Group

Hanford contractors meet to coordinate actions and share ideas on the how to implement the revised standard. Members are made of training managers, HAZCOM subject matter experts, chemical management program personnel, industrial hygienists, CITS and SDS administrator. (Best Practice) DOE Letter of Direction to MSA, G. H. Branch/RL J. F. to Armijo/MSA Correspondence #1204857 A dated 11/05/2012.

Group meetings started in April 2012 and keep meeting per need at HAMMER Facility. See the GHS Web Page for meeting schedule, dates and minutes.

HAZCOM section part of Hanford General Employee Training (HGET)

Training material was revised by training managers and HAZCOM subject matter experts. The revised material included a GHS video and new slide on the new GHS elements. This training meets the OSHA requirements of providing workers initial GHS-HAZCOM training on the GHS elements by December 2013. (29CFR1910.1200 (j)(1) Effective Dates)

HGET is required annually for all Hanford employees. The new GHS HAZCOM part of HGET training was began November 2012 and completed by all Hanford employees by the OSHA deadline of December 2013. Training for new workers requires watching the five minutes GHS HAMMER video. Video is optional when retaking the training.

GHS Web Page Establish a web page to Announce available training and other activities; provide links to tools, resources, and related information; identify points of contact; and highlight communications.

GHS Web Page established May 2012 and is updated regularly.

Transition Communication

Comments / Questions