Transcript Presentation Title - Permian Basin STEPS

HCS and GHS
Sheila Schulmeyer, CAS, LDO
GHS
• On September 30, 2009 OSHA
issued a proposed rule to aligned the
OSHA Hazard Communication
Standard (HCS) with the Globally
Harmonized System of Classification
and Labeling of Chemicals (GHS)
• On March 20, 2012 OSHA issued
the Final Rule aligning the HCS to
the GHS.
GHS
• The benefits include enhanced worker
comprehension resulting in appropriate handling
and use of chemicals. The harmonized format of
the safety data sheets will enable workers to
access the information more efficiently
• Also currently multiple labels and safety data
sheets must often be developed by chemical
manufacturers for the same product when
shipped overseas. This creates a major
compliance burden increasing costs
GHS
• The benefit of the new system is that it provides a
single set of criteria for classifying chemicals
according to their health and physical hazards
and specifies hazard communication elements for
labeling and safety data sheets
• The new HCS labels include signal words,
pictograms, and hazard and precautionary
statements
• The Safety Data Sheets (SDS) will have a
standardized format
GHS
• The major changes to the HCS include:
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Hazard Classification
Labels
Safety Data Sheets
Information and Training
• The new HCS will affect nearly 40 million
workers and 5 million workplaces and estimated
to prevent 43 deaths and 585 injuries and
illnesses annually
GHS
• The DOT has already
modified their requirements
for classification and labeling
to be consistent with UN
transport requirements and
the GHS
GHS Hazard Classification
• The list of chemicals presenting a ‘Health’
hazard was deleted from the current HCS and
the proposed HCS has identified a new listing
• A ‘Health Hazard’ means a chemical which is
classified as posing one of the following
hazardous effects:
HCS Hazard Classification
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Acute Toxicity (any route of exposure)
Skin Corrosion or Irritation
Serious Eye Damage or Eye Irritation
Respiratory or Skin Sensitization
Germ Cell Mutagenicity
Carcinogenicity
Reproductive Toxicity
Specific Target Organ Toxicity (single or repeated
exposure)
– Aspiration Hazard
HCS Hazard Classification
• The list of chemicals presenting a ‘Physical’
hazard was deleted from the current HCS and
the proposed HCS has identified a new listing
• A ‘Physical Hazard’ means a chemical that is
classified as posing one of the following
hazardous effects:
HCS Hazard Classification
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Explosive
Flammable (gases, aerosols, liquids, or solids)
Oxidizer (liquid, solid, or gas)
Self-Reactive
Pyrophoric (liquid or solid)
Self-Heating
Organic Peroxide
Corrosive To Metal
Gas Under Pressure
Contact With Water Emits Flammable Gas
HCS Hazard Classification
• The HCS does not address environmental
hazards and OSHA does not have jurisdiction
over that. There are environmental hazard
classifications:
– Hazardous to the Aquatic Environment
• Acute Aquatic Toxicity
• Chronic Aquatic Toxicity
– Bioaccumulation Potential
– Rapid Degradability
OSHA Hazard Classification
• In OSHA’s HCS standard there is a hazard
category called ‘Hazards Not Otherwise
Unclassified’ (HNOC) which is not in the UN GHS
system…
– ...means an adverse physical or health effect
identified through evaluation of scientific
evidence during the classification process that
does not meet the specific criteria for the
physical and health hazard classes addressed
in this section
OSHA Hazard Classification
• Hazards Not Otherwise Classified (HNOC) will
not be required to be listed on the label but will
be disclosed in Section 2 (Hazards Identification)
of the SDS
• Combustible Dusts, Simple Asphyxiants, and
Pyrophoric Gasses were removed from the
HNOC and will be treated individually as
hazardous chemicals
• Will be addressed on labels and SDS with signal
words and hazard statements
HCS Labels
• Three standardized HCS label elements:
– Symbols (Hazard Pictograms) that convey health,
physical, and environmental hazard information
assigned to a GHS hazard class and category
– Signal Words “Danger” or “Warning” used to
emphasize hazards and relative level of severity
of the hazard and assigned to a GHS hazard
class and category
– Hazard Statements which are standard phrases
assigned to a hazard class and category that
describe the nature of the hazard
HCS Labels
HCS Pictograms
Red
border
GHS
-----Black
border
Transport
HCS Pictograms
Hazard Classes may have ‘Categories’
Safety Data Sheets (SDS)
• The OSHA ‘Material Safety Data Sheet’ (MSDS)
is now called a ‘Safety Data Sheet’ (SDS)
• The MSDS had 8 non-mandatory sections
• The SDS has 12 mandatory and 4 nonmandatory sections and is essentially the ANSI
Z400.1-2004 format
– Sections 12-15 are not mandatory and cover
Ecological, Disposal, Transport, and Regulatory
information
Safety Data Sheets (SDS) Sections
– 1. Identification
– 2. Hazard(s) identification
– 3. Composition/ information
on ingredients
– 4. First-Aid measures
– 5. Firefighting measures
– 6. Accidental release
measures
– 7. Handling and storage
– 8. Exposure controls/
personal protection
• 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 information,
including date of
preparation/revision
Not required by OSHA
Safety Data Sheets (SDS)
What a New ‘SDS’ May Look Like
The old Non-Mandatory ‘MSDS’
HCS Information and Training Dates
• December 1, 2013 workers must be trained on the
new labels and Safety Data Sheets
• June 1, 2015 chemical manufacturers, importers,
distributors, and employers etc. must be in
compliance with all modified provisions of the HCS
• June 1, 2016 employers must update alternative
workplace labeling and hazard communication
programs as necessary, and provide additional
worker training for new identified physical and
health hazards
HCS Information and Training Dates
• Distributers may ship products labeled by
manufacturers under the old system until
December 1, 2015
• Six months to revise and use new labels
when significant information about a
chemical is discovered
• SDS will still be required to have ACGIH
TLVs and OSHA PELs listed
HCS Appendices
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Appendix A: Health Hazard Criteria
Appendix B: Physical Hazard Criteria
Appendix C: Allocation of Label Elements
Appendix D: Safety Data Sheets
Appendix E: Definition of ‘Trade Secret’
Appendix F: Guidance for Hazard Classification
Regarding Carcinogenicity
GHS Changes in the Future
• The HCS will be updated as needed to reflect
new technology and scientific developments, or
provide explanatory text. Changes to the HCS is
anticipated through:
– Technical Updates for minor terminology changes
– Direct Final Rules for text clarification
– Notice and Comment Rulemaking for more
substantive or controversial updates such as
additional or changes in health or safety hazard
classes or categories
Resources
• The GHS is going to
be found in the ‘GHS
Purple Book’
• You can purchase
from the UN bookstore
if you are looking for
information related to
the GHS
Resources
• On the OSHA website
under ‘Safety and Health
Topics’ there is a Hazard
Communication
webpage with many
resources and
documents such as the
Federal Register, ‘Old’ http://www.osha.gov/dsg/hazcom/index.html
vs ‘New’ standard
comparison…
Resources
Resources
• OSHA published ‘A
Guide to The Globally
Harmonized System
of Classification and
Labeling of Chemicals
(GHS)
• It can be downloaded
from the OSHA
website
Where is OSHA Located?
Lubbock District Office
1205 Texas Ave., Room 806
Lubbock, Texas 79401
806-472-7681
Sheila Schulmeyer, CAS
[email protected]
Ext at above number is 227
Disclaimer
•
This information has been developed by an OSHA Compliance Assistance
Specialist and is intended to assist employers, workers, and others as they
strive to improve workplace health and safety. While we attempt to
thoroughly address specific topics [or hazards], it is not possible to include
discussion of everything necessary to ensure a healthy and safe working
environment in a presentation of this nature. Thus, this information must be
understood as a tool for addressing workplace hazards, rather than an
exhaustive statement of an employer’s legal obligations, which are defined
by statute, regulations, and standards. Likewise, to the extent that this
information references practices or procedures that may enhance health or
safety, but which are not required by a statute, regulation, or standard, it
cannot, and does not, create additional legal obligations. Finally, over time,
OSHA may modify rules and interpretations in light of new technology,
information, or circumstances; to keep apprised of such developments, or to
review information on a wide range of occupational safety and health topics,
you can visit OSHA’s website at www.osha.gov.