Transcript GHS Rev*s to OSHA HCS

Bill Balek
ISSA
July 31, 2013
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Today’s Session
Employee Education and Training
 Revised OSHA Hazard Communication Standard
 Due Dec. 1, 2013
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Background
 March 20, 2012:
OSHA issues final rule
 GHS revisions to Hazard
Communication Standard
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Background
OSHA HCS Governs:
 Chemicals
 MSDSs
 Labels
 Employee education and training
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Purpose: Avoid chemical injury and illnesses
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Background
1985: OSHA issues HCS
 Labeling, MSDS for hazardous chemicals
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2001: Globally Harmonized System of
Classification and Labeling of Chemicals
(GHS)
UN members agree to adopt GHS by 2008
2012: GHS Revisions to HCS
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What remains the same under GHS Rev’s?
Basic structure
 Manufacturers: Classify chemicals and provide
SDS, labels to downstream customers
 Distributors: Pass SDS and labels downstream
 Employers: Employee education and training
 Avoid chemical injuries and illnesses
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What’s changed? Tactics.
Classification of hazards (Manufacturer)
SDS: redraft to comport with new format,
pictograms, etc. (Manufacturer)
Labeling (Manufacturer)
 More prescriptive, uniform language
 Pictograms
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Implications for Cleaning industry
 Chemical Manufacturers
 Distributors
 Cleaning Service Providers
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Implications for Chemical Manufacturers
Obligations that run to downstream
customers
 Re-classify products
 Re-draft SDSs
 Re-do labels
 June 1, 2015
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Implications for Distributors
Obligations that run to downstream
customers
 Send new GHS SDS (June 1, 2015)
 Ship products with new GHS labels (Dec. 1, 2015)
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Implications for “Employers”
Employers: Manufacturers, Distributors,
Cleaning Service Providers
 Employee education and training
 New label elements
 New SDS format
 Dec. 1, 2013
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New Labeling Elements
Effective June 1, 2015
 Distributors
 Dec. 1, 2015
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Permissible to comply earlier
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Safety Data Sheets (SDS)
 Formerly MSDS
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New 16 section uniform format
Effective June 1, 2015
Permissible to comply earlier
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Workers may see GHS labels, SDS soon…
OSHA requires employee training
 New label elements
 New SDS format
 Dec. 1, 2013
 Ensure workers have info to protect themselves
 Understand GHS labels and SDS
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Product identifier
Signal word
Hazard statement
Pictograms
Precautionary statement(s)
Name, address, telephone number of
manufacturer or other responsible party
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Signal word
Hazard statement
Pictograms
Harmonized label elements
 Based on hazard class and hazard category
 In general, manufacturer has no discretion
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Product identifier
 Name of product
 Same as on SDS
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Signal word
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Indicates severity of hazard
Danger: more severe hazards
Warning: less severe hazards
Only one signal word on the label
Not all hazards have signal words
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Hazard statement
 Describes the nature of the hazard
 “Causes skin irritation”
 “Flammable liquid and vapor”
 All applicable hazard statements must be on label
 Uniform (mandatory Appendix C)
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Pictograms
 Images that communicates the hazard
 Square on point
 Black hazard symbol
 White background
 Red border
 Red border minus hazard symbol NOT allowed
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Skin corrosion, burns
Eye damage
Corrosive to metals
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Flammable
Pyrophorics
Self-heating
Emits flammable gas
Self-reactive
Organic peroxides
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Oxidizer
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Gases under pressure
Carcinogen
Mutagenicity
 Reproductive toxicity
 Respiratory Sensitizer
 Target organ toxicity
 Aspiration toxicity
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Explosives
Self-reactives
Organic peroxides
Acute toxicity (fatal
or toxic)
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Irritant (skin, eye)
Skin sensitizer
Acute toxicity
Narcotic effects
Respiratory tract irritant
Hazardous to ozone
layer
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Aquatic toxicity
Non-mandatory
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Precautionary Statements
 Recommended measures to prevent or minimize
adverse effects from exposure , improper storage
or handling
 What to do to prevent harmful exposure
▪ Wash thoroughly after handling
▪ Wear protective gloves
 What to do if there is harmful exposure
▪ If eye irritation persists, get medical advice
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Name, address, telephone number of
manufacturer or other responsible party
Address
 City and state sufficient
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Telephone number
 New requirement
Pictogram
Product Identifier
Signal Word
XYZ Cleaner
Warning
XYZ Manufacturing Co.
Chicago, IL
312.123.4567
Manufacturer
Causes serious eye irritation
Hazard Statement
Wash hands thoroughly after handling. Wear eye protection.
Store in a cool dry place.
First Aid
If in eyes, rinse cautiously with water for several minutes.
Remove contact lenses, if present, and easy to do. Continue
rinsing. If eye irritation persists: get medical attention.
Precautionary Statement
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Make sure employees know…
 How to go from label to SDS
 How to use label to
▪ Properly store product
▪ Work with product safely
▪ Avoid harmful exposure
 What to do in event of harmful exposure
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Where product has multiple hazards
 Multiple pictograms, hazard statements
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Standardized 16-section format
SDS must be presented in a consistent order
 Sec. 1: Identification
▪ Product identifier used on label
▪ Recommended use of the chemical
▪ Name, address and telephone number of manufacturer,
importer or other responsible party
▪ Emergency phone number
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Standardized 16-section format
 Sec. 2: Hazard identification
▪ Hazard class, and category (i.e., flammable liquid,
category 4)
▪ Label elements:
▪ Signal word (i.e., Warning)
▪ Hazard statement (i.e., combustible liquid)
▪ Pictograms (none for flammable liquid, cat. 4)
▪ Precautionary statement
▪ Consistent with label / “Heart” of SDS
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Standardized 16-section format
 Sec. 3: Composition/information on ingredients
▪ Information on chemical ingredients, trade secrets
 Sec. 4: First-aid measures
▪ Description of measures based on route of exposure
▪ Immediate medical treatment
 Sec. 5: Fire fighting measures
▪ Suitable and unsuitable extinguishing media
▪ Special hazards presented by the chemical in fire
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Standardized 16-section format
 Sec. 6: Accidental release measures
▪ Personal precautions, emergency procedures
 Sec. 7: Handling and storage
▪ Precautions for safe handling and storage
▪ Any incompatibilities
 Sec. 8: Exposure controls / personal protection
▪ OSHA PELs, TLVs
▪ Appropriate engineering controls (ventilation
▪ PPE
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Standardized 16-section format
 Sec. 9: Physical and chemical properties
▪ Appearance, pH, odor, flash point, vapor pressure, etc.
 Sec. 10: Stability and reactivity
▪ Chemical stability, possibility of hazardous reactions
▪ Conditions to avoid, incompatible materials
 Sec. 11: Toxicological information
▪ Routes of exposure, related symptoms, acute and
chronic effects
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Standardized 16-section format
 SDS must contain sections 12-15, but…
 OSHA will not enforce the content for these
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Sections
Sec. 12: Ecological information
Sec. 13: Disposal considerations
Sec. 14: Transportation information
Sec. 15: Regulatory information
Sec. 16: Date of preparation, last revision
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Info must be presented in manner workers
can understand
 Non-english speaking workers
 Illiterate
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Recommend: Keep record of employees
trained
 Sign in log
 Training materials used
 Tests
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If you would like a certificate indicating you
have been trained consistent with the GHS
HazCom Training requirements…
Email: [email protected]
Subject Line: CERTIFICATE
Short Test
Upon passing test, certificate will be issued
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ISSA Resources
Detailed Summary: www.issa.com/ghshcs
Manufacturers: Formulator Webinar Series
 Reclassification, SDS, Labels
 [email protected]: Formulator Webinar
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Employee Education and Training (Dec. 1, 2013)
 Webinar: July 31
 Online training: www.issa.com/ghs
 Resources: www.issa.com/ghstraining
Questions???
Bill Balek, ISSA
[email protected]
800.225.4772