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Hazard Communication Program / Globally Harmonized System American Safety & Health Haz Com History Late 1970’s-- “Right to Know” Early 1980’s--City Ordinances/State Laws 1983—Hazard Communication “HCS” enacted 1994– “HCS 1994” Federal Law revised March 2012– “HCS 2012” Globally Harmonized System OSHA revises HCS to align with GHS Right to Know to Right to Understand Requirements of the Standard SDS Labeling Written Program Inventory Training Common HazCom Citations Standard 1910.1200 (e) 1910.1200 (f) 1910.1200 (g) 1910.1200 (h) Subject Failure to develop a written program Failure to label containers Failure to have an MSDS for each hazardous chemical Failure to train employees Haz Com / GHS Overview What is it? 29 CFR 1910.1200 & 1926.59 How will GHS change your HazCom Program? When will this happen? What do you need to do now? What is GHS? The Globally Harmonized System (GHS) is an international approach to hazard communication United Nations' document on Globally Harmonized System of Classification and Labeling of Chemicals (purple book) Harmonizes hazardous chemical classification and communication (Labels and SDS) Hazard Communication and GHS Will everything change? Many program elements are similar, but not exactly alike Not a total re-write of the standard Two most prevalent changes: •Hazard Classification •Health and Physical Hazards Hazard Communication •Labels •Safety Data Sheets Why Modify the HCS? The frame work won’t change. Improve quality Consistency of hazard information. Align HCS with GHS will enhance workers understanding of hazards. Reduces trade barriers. What’s Next ? Effective Completion Date December 1, 2013 Requirement(s) Train employees on the new label elements and safety data sheet (SDS) format. Who Employers What’s Next? Effective Completion Date Requirement(s) Who June 1, 2015* Compliance with all modified provisions of this final rule, except: December 1, 2015 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 *This date coincides with the EU implementation date for classification of mixtures What’s Next? Effective Completion Date Requirement(s) Who 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 Aspects of OSHA’s GHS Approach Terminology has been changed to be consistent with the GHS where necessary ◦ Most common changes are “hazard classification” (rather than hazard determination) and “safety data sheet” (rather than material safety data sheet) GHS provisions have been put into OSHA mandatory language Bulk of technical requirements in Appendices Hazard Classification Each health and physical hazard is a “hazard class” A “hazard class” may also be sub-divided into several “hazard categories” based on the degree of severity of the hazard This is the concept of classification— determining both that there is a hazard, and what the severity is Health Hazard Classes— Appendix A Acute toxicity Skin corrosion/Irritation Serious eye Carcinogenicity Reproductive toxicology Target organ systemic damage/eye Irritation Respiratory or skin sensitization Germ cell mutagenicity toxicity - single exposure Target organ systemic toxicity - repeated exposure Aspiration toxicity Physical Hazard Classes Appendix B Explosives Flammable gases Flammable aerosols Organic peroxide Gases under pressure Flammable liquids Flammable solids Self-reactive substances Pyrophoric liquids Pyrophoric solids Self-heating substances Emits flammable gases on contact with water Oxidizing liquids, gas, & solids Corrosive to metals Labeling Purpose—immediate warning Identity, hazards, and safe use All containers are labeled Types: GHS Labels Linked to Hazard Class and Category Company labels HMIS, NFPA Someone responsible Zip Cleaner Labeling At the source of potential contact with a chemical, a container label provides: important information about how to handle that chemical safely. While they’re not as informative as Safety Data Sheets, it’s critical that an appropriate identifying label is affixed to any container that holds hazardous chemicals. 2 Basic “Uniform Labels” Prior to 2012 NFPA—National Fire Protection Association HMIS—Hazardous Material Identification System Both types must identify the chemical name and hazards Chemical Name Health Hazard Fire Hazard Flash Points 4-Deadly (red) 3-Extremely Hazardous 2-Hazardous 4-Below 73 F 3-Below 100 F (blue) 1-Slightly Hazardous 2-Below 200 F 0-Normal material 1-Above 200 F 0-Will not burn Specific Hazard Reactivity Oxidizer OXY 4-May detonate Acid ACID Alkali ALK 3-Shock and heat may detonate Corrosive COR Use NO WATER W Radiation Hazard (white) (yellow) 2-Violent chemical change NFPA Label 1-Unstable if heated 0-Stable HMIS LABEL Health (blue) Flammability (red) Reactivity (yellow) Personal Protective Equipment (white) Chemical Name:______________________________ Workplace Labeling of Chemicals If chemicals are placed in another container, this new container must have a label Workplace labels –alternative labels for secondary labels are allowed Portable container exemption Chemical Labels GHS Format How will labels change under the revised Hazard Communication Standard? Labels will cover physical, health and environmental hazards Pictograms- Nine different ones Signal Words - Danger and Warning Hazard Statement Precautionary Statement - Workplace Labeling Example: Flammable liquids GHS Category 1: Extremely flammable liquid and vapour Category 2: Highly flammable liquid and vapour Category 3: Flammable liquid and vapour Category 4: Combustible liquid While the hazard category number doesn’t appear on the label, consider: GHS Category 1- Highest 2- High 3- Medium 4- Low HMIS/NFPA 704 4- Extreme 3- High 2- Moderate 1- Slight GHS Labels Among the possible hazards that may be represented by these symbols: oxidizers, flammables, explosives, acute toxicity, corrosives, gases under pressure, carcinogen, environmental toxicity, and irritant. An entirely separate set of pictograms is used for the transport of hazardous materials. GHS PICTOGRAMS Health Hazard Health Hazard Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity Flame Flame Flammables Pyrophorics Self-Heating Emits Flammable Gas Self-Reactives Organic Peroxides Exclamation Point Exclamation Point Irritant (Skin & Eye) Skin Sensitizer Acute Toxicity Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (NonMandatory) Gas Cylinder Gas Cylinder Gases Under Pressure Corrosion Corrosion Skin Corrosion / Burns Eye Damage Corrosive to Metals Exploding Bomb Exploding Bomb Explosives Self-Reactives Organic Peroxides Flame Over Circle Flame Over Circle Oxidizers Environment Environment (Non-Mandatory) Aquatic Toxicity Skull & Crossbones Skull & Crossbones Acute Toxicity (Fatal or Toxic) Safety Data Sheets •Purpose—show comprehensive chemical safety information •SDS for each hazardous material •Readily Accessible/complete/retain •Provide Copies to employees when requested •When working at different locations •16 part format •Someone responsible Safety Data Sheets Appendix D There are 16 sections in the safety data sheet. Each section has a specified sequence and minimum information requirements. Will not enforce sections 12-15 that require information outside OSHA’s jurisdiction Based on ANSI Z400 Safety data sheet sections and sequence 1. Identification 2. Hazard(s) identification 3. Composition/information on 4. 5. 6. 7. 8. ingredients First-aid measures Fire-fighting measures Accidental release measures Handling and storage Exposure Controls/PPE 9. Physical and chemical properties 10. Stability and reactivity 11. Toxicological information 12. Ecological information* 13. Disposal considerations* 14. Transport information* 15. Regulatory information* 16. Other Info - Date prepared/revised * Regulated by other Agencies Hazard Communication Training Employers shall provide employees with effective information and training on hazardous chemicals at; The time of initial assignment Whenever a new hazard is introduced When transferring When returning from extended leave Haz Com Training for SDS The material safety data sheet (MSDS) is now a safety data sheet (SDS). Explain the sequence of order in regard to the information on the SDS. Explain the labeling system (for received materials as well as the workplace labeling system). General Training Hazard Communication Standard Employer’s Written Program Location/Availability Of Written Program & SDS How to read labels & SDS’s Specific Training Characteristics - How to detect Health & Physical Hazards Work practices or SOPs Emergency action plans Personal Protective Equipment (PPE) Non-routine tasks Industrial Hygiene monitoring results Written program: Developed, implemented, and maintained • • • • • Chemical inventory Safety data sheets Labeling Training Misc. Non-Routine Tasks Piping Systems Contractors/Multi-Employer Worksites