Transcript - Marine Chemist Association

Global Harmonization System
Stephanie Carver
July 16, 2013
Agenda

Haz Com 2012
 GHS
Overview
 Revised Definitions
 Hazard Classifications
 Labeling
 SDS
Time Line

September 30, 2009
Proposed Rule in the Federal Register

March 26, 2012
Final Rule published in the Federal Register

Effective Dates
December 1, 2013 – employee training
June 1, 2015 – classification, labeling and SDS
implementation
December 1, 2015 – no longer ship with old labels
June 1, 2016 – additional employee training for newly
identified hazards
GHS Overview
Based on UN program to develop a
standard system for classifying and
communicating hazards for chemicals
 This will affect employees, consumers,
transportation and emergency responders
 These changes to Haz Com with help
ensure there is a clear, defined means of
communicating hazards globally

GHS Overview




Significant overhaul of HCS
Inclusion of other hazards and
provisions for HNOC
Adoption of GHS classification
and labeling
SDS format and specific
content requirements
GHS Overview

DOT (Department of Transportation), EPA
(Environmental Protection Agency) and
CPSC (Consumer Product Safety
Commission) were actively involved in
developing GHS
 DOT
has already modified their requirements
for classification and labeling to be consistent
with GHS
 EPA using in the DfE Program Best Practices
approach
Overview of New HCS


Affected 29 CFR Parts 1910 (General), 1915
(Shipyard) and 1926 (Construction)
Significant Changes to HCS
 Terminology and definitions
 Define substance and mixture
 Classification not determination
 Classification
according to GHS
 Labeling
 SDS
 GHS
“shall” will replace “should” under OSHA
Revised Definitions

Chemical
 Any

substance or mixture of substances
Hazardous Chemical
 Any
chemical which is classified as a physical hazard
or a health hazard, a simple asphyxiant, combustible
dust, pyrophoric gas, or hazard not otherwise
classified
 vs. old language: “any chemical which is a physical
hazard or a health hazard”

Physical Hazards – definitions deleted and
placed in a new Appendix B
Revised Definitions

Simple asphyxiant
 Substance

or mixture that displaces oxygen
Combustible dust
 No
definition but rather a reference to OSHA’s
“Hazard Communication Guidance for Combustible
Dusts”(3371-08-2009) and Combustible Dust National
Emphasis Program Directive CPL 03-00-008

Pyrophoric gas
 A chemical
in gaseous state that will ignite
spontaneously in air at a temperature of 130oF
(54.4oC) or below
Revised Definitions

New Terms
 Hazard
category and subcategory
 HNOC
 Hazard
statement
 Label elements
 Pictograms
 Precautionary statements
 Product identifier
 SDS
 Signal word
Revised Definitions

Hazard Category and Subcategory
 The
division of criteria within each hazard
class. These categories compare hazard
severity within a hazard class and should not
be taken as a comparison of hazard
categories.
 Example:
Toxicity old HCS defined as “not”, “slight”, “toxic”
 New HCS has Categories 1 – 4 based on ATE for
each category

Revised Definitions

HNOC
Not Otherwise Classified – formerly
called “Unclassified Hazards”
 Hazards covered under hazcom but not
currently addressed by the GHS
 Not required to be on the label but will be
required to be listed in Section 2: Hazard
Identification of the SDS
 Must be addressed in worker training
 Hazard
Revised Definitions

HNOC
 Must
be assessed when the manufacturers
and importers evaluate physical and health
hazards
 Pyrophoric gases, simple asphyxiants and
combustible dust were removed from
unclassified (HNOC) and are addressed
individually

Must be addressed on labels where appropriate
Classification

means to identify the relevant data regarding the
hazards of a chemical; review those data to
ascertain the hazards associated with the
chemical; and decide whether the chemical will
be classified as hazardous according to the
definition of hazardous chemical in this section.
In addition, classification for health and physical
hazards includes the determination of the
degree of hazard, where appropriate, by
comparing data with the criteria for health and
physical hazards.
Classification

Manufacturers and importers are required to reevaluate chemicals according to the new criteria
in order to ensure the chemicals are classified
appropriately.
 This
pertains to the product not the individual
chemicals (paint is not evaluated as a combustible
dust)
 Health hazards – assign the chemical both a hazard
category and subcategory
 Physical hazards – new criteria consistent with
current DOT requirements
Classification

Health Hazards
 1910.1200 Appendix A –
Health Hazard
Criteria
Outlines the process for determining hazards
 Extensive so more time consuming for
manufacturers

Revised Definitions

Hazard Statement
 Assigned
to a hazard class and category that
describes the nature of the hazard(s) of a
chemical including, where appropriate, the
degree of hazard

Signal word
 One
of two words used to distinguish between
hazard levels and emphasize the extent of the
hazard

DANGER or WARNING
Revised Definitions

Pictograms
 A visual
depiction that may include a symbol
and other graphic elements intended to
convey specific information
 Eight designated under this standard for
hazard category
 Red borders required on all labels
Pictograms
• Flammables
• Pyrophorics
• Self heating substances &
mixtures
• Substances & mixtures
when in contact with
water emit flammable
gases
• Organic peroxides
Defines flammability
Pictograms
• Oxidizers
Defines an Oxidizer
A chemical which may, generally by providing oxygen, cause
or contribute to the combustion of other material
Pictograms
• Gases under pressure
Defines all types of gases
Pictograms



Defines
Explosives
Self-reactives
Organic Peroxides
Pictograms
• Skin corrosion, burns
• Eye damage
• Corrosives to metals
Defines both physical & health hazards
• Corrosive to metals
• Corrosive to skin or eyes
Pictograms
•
•
•
•
•
•
Defines chronic & specific
long term type effects
Carcinogen
Mutagenicity
Reproductive toxicity
Respiratory sensitizer
Target organ toxicity
Aspiration toxicity
Pictograms
• Acute toxicity
Defines acute toxicity (fatal or toxic)
Toxicity based on LD50 and other lab based testing
Pictograms
Defines lower level
toxicity and irritation effects
•
•
•
•
Irritant to skin & eyes
Skin sensitizer
Narcotic effects
Respiratory tract
irritant
• Hazardous to ozone
layer (not mandatory)
Pictograms
• Based on aquatic
toxicity only
• Chronic based on
toxicity & persistence in
the environment
Defines Aquatic Toxicity
(Optional)
Revised Definitions

Precautionary Statements
 Phrases
that describe measures
recommended to minimize or prevent adverse
effects resulting from exposure, improper
storage or handling

Product Identifier
 The
name of the product and any other
manufacturer reference (ie code number)
Revised Definitions

Label Elements
 Product
Name and Codes (SDS Sections 1,
3, 14)
 Pictogram (SDS Section 2)
 Hazard statement (SDS Section 2)
 Signal word (SDS Section 2)
 Precautionary statement (SDS Section2)
 Supplier Information (SDS Section 1)
Revised Definitions

Label Elements
Revised Definitions

Label Differences
Current OSHA Template
• Identity of hazardous chemical
• Hazard warnings
• Contact information for
manufacturer/importer/responsible
party.
GHS Template
•
Product Identifier
•
Pictograms
•
Signal word
•
Precautionary Statements
•
Hazardous Statements
•
Supplemental Information
•
Supplier Identification
Revised Definitions

Safety Data Sheet
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
Identification
Hazard Identification
Composition / information on ingredients
First aid measures
Fire fighting measures
Accidental release measures
Handling and storage
Exposure controls / personal protection
Physical and chemical properties
Stability and reactivity
Toxicological information
Ecological information
Disposal considerations
Sections 12-15
outside OSHA
Transport information
Regulatory information
Other information including preparation and revision dates
HCS Continues
ACGIH TLV’s continue to be required by
OSHA
 Information on carcinogenicity
classifications by IARC and NTP
 Process for handling trade secret
information is not changed

Impacts

Manufacturers/Importers
 Re-classification
to meet new standards
 Create new SDS/Labels
 Ensure documents are distributed

Employers
 Manage
new SDS
 Classification impacts
 Container labeling
 Re-educate workers
 Maintain up to date information
Implementation Dates

December 1, 2013
 employee

training
June 1, 2015
 classification,
labeling and SDS
implementation

December 1, 2015
 no

longer ship with old labels
June 1, 2016
 additional
employee training for newly
identified hazards
Employee Training at BIW
GHS??