1. Chemical Hazard Communication Standard
Globally Harmonized System of Classification and Labeling of Chemicals WAC
Introduce self
Introduce topic
Pam Edwards , IH, MS
Technical Service DOSH
Olympia , WA

2. Overview What is the Globally Harmonized System?
What changed in OSHA’s new Chemical Hazard Communication standard?
SDS
Labels
What about DOSH/Resources?
Click to reveal each item:
What is chemical hazard communication?
What is the Globally Harmonized System?
What changed in OSHA’s new Chemical Hazard Communication standard?
What about WISHA?
Resources

3. What is the Globally Harmonized System (GHS)?

4. What is the GHS?
Harmonized criteria for the classification of substances and mixtures according to their health, environmental and physical hazards.
Harmonized hazard communication system including requirements for labelling and safety data sheets.
Target Audience - workers, employers, consumers, transport workers, emergency responders

5. The current edition is the 4th; revision continue on a 2-year cycle
The current edition is the 4th; revision continue on a 2-year cycle. So far, most have been text clarifications.

6. Agencies Involved with the GHS
Federal Washington State USEPA DOE & WSDA DOT WSDOT OSHA L&I / DOSH CPSC
The DOT was actually the first American agency to implement GHS and OSHA’s adoption brings the regulations between those two agencies into greater harmony. The EPA is expected to follow closely on the heels of OSHA’s adoption with revisions to its own standards to bring them into alignment with GHS.

7. Dark green: Countries/regions that have already implemented GHS.
Light green: Countries/regions where GHS is voluntary. Yellow: Countries/regions that are in the process of implementing GHS.
Blue: Countries/regions where GHS is not implemented or not available.
To date, over 65 countries have adopted GHS or are in the process of adopting GHS.

8. OSHA’s new GHS-based Hazard Communication Standard
Adopted March 26, 2012
“HazCom 2012”
On March 26, 2012, OSHA revised the Hazard Communication Standard to align with the GHS.
OSHA calls the new version “HazCom 2012.”

9. Hazcom 2012 Standard Published March 26, 2012
Conform to the Globally Harmonized System for the Classification and Labelling of Chemicals (GHS) Rev 3
Changes to
Classification
Label Content
Safety Data Sheet Content (mandatory 16 section SDS, % required)
No Changes to
Scope and Exemptions
Written Hazcom Program
Labeling requirement
MSDS Distribution and Availability in the Workplace
Employee Information and Training (other than training on new labels and MSDS within 2 years)
Trade Secrets (except to include percentage)

10. Labeling exemptions Pesticides
Toxic Substances Control Act (TSCA) regulated chemicals
Food, food additives, color additives, drugs, cosmetics, medical/veterinary devices, alcoholic beverages
Consumer products when labeled in accordance with the Consumer Product Safety Commission (CPSC)
Seeds treated with pesticides if labeled under US Department of Agriculture (USDA)

11. Label and SDS Exemptions
Hazardous waste
Hazardous substances at a CERCLA remediation site
Tobacco
Wood and wood products which will not be processed and only present a fire hazard
Articles
Food and alcoholic beverages sold, used or prepared in retail establishments or intended for personal consumption

12. Major Changes Labels & (M)SDS No longer performance-based.
Each hazard class and category has specified hazard statement(s), signal word, pictogram(s), and precautionary statement(s) in mandatory Appendix C. Those elements must appear on the label and (M)SDS.

13. What changed in the Haz Com standard?
Hazard determination
Now titled “hazard classification”
Detailed data-based criteria
Health hazard criteria in mandatory Appendix A and non-mandatory Appendix F
Physical hazard criteria in mandatory Appendix B
Specified; no longer performance-based

14. Classification of chemical hazards (Appendices A & B)
Hazard class: the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute toxicity.
Hazard category: division by degree or type of hazard within each hazard class.
Appendix A discusses health hazards, and Appendix B discusses physical hazards.
Hazard Class: Describes the nature of the physical or health hazards For example, "Gases under Pressure" is an example of a class in the physical hazards group.
Hazard Category: Describes the degree of hazard within a class. The specific criteria varies with the type of hazard.

15. Hazard Category (health hazard criteria, Appendix A)
Hazard Class
Hazard Category (health hazard criteria, Appendix A)
Acute toxicity 1 2 3 4
Skin corrosion/irritation 1A 1B 1C
Serious eye damage/irritation 2A 2B
Respiratory or skin sensitizers
Germ cell mutagenicity
Carcinogenicity
Reproductive toxicity
lactation
Specific target organ toxicity - single exposure
Specific target organ toxicity - repeated exposure
Aspiration
These are the hazard classes and categories for health hazards, from Appendix A.

16. Hazard Category (physical hazard criteria, Appendix B) Explosive
Hazard Class
Hazard Category (physical hazard criteria, Appendix B)
Explosive
Unstable
Div 1.1
Div 1.2
 Div 1.3
Flammable gases 1 2
Flammable aerosols
Oxidizing gases
Gases under pressure
Compressed
Liquefied
Refrigerated liquefied
Dissolved
Flammable liquids 3 4
Flammable solids
Self-reactive A B C D E F G
Pyrophoric liquids
Pyrophoric solids
Self-heating
Emits flammable gas when in contact with water
Oxidizing liquids
Oxidizing solids
Organic peroxides
Corrosive to metals
These are the hazard classes and categories for physical hazards, from Appendix B.

19. Exploding Bomb Symbol Unstable Explosives
Explosives (Divisions )
Self-reactives (Type A and Type B with Flame)
Organic Peroxides (Type A and Type B with Flame)

20. Flame Symbol Flammable Gases Flammable Aerosols
Flammable Liquids (Categories 1-3)
Flammable Solids
Self-Reactives (Type B with bomb, Types C-F)
Pyrophoric liquids and solids
Self-heating substances
Substances which in contact with water emit flammable gases
Organic Peroxides (Type B with bomb, Types C-F)

21. Flame over Circle Symbol
Oxidizing Gases
Oxidizing Liquids
Oxidizing Solids

22. Gas Cylinder Symbol Compressed Gas Liquefied Gas
Refrigerated Liquefied Gas
Dissolved Gas

23. Corrosion Symbol
Corrosive to Metals (steel or aluminum >6.25 mm/year at 55C)
Skin corrosion/ irritation – Category 1 (A, B and C)
Serious eye damage/ irritation – Category 1

24. Skull and Crossbones Symbol
Acute Toxicity – Categories 1-3 (oral, inhalation or dermal routes)

25. Exclamation Mark Symbol
Acute Toxicity – Category 4 (oral, inhalation or dermal routes)
Skin Irritation/ Corrosion – Category 2
Serious Eye damage/ irritation – Category 2A
Skin Sensitizer
STOST (single exposure) – Category 3 (respiratory tract irritation, narcotic effects)
Hazardous to the Ozone Layer

26. Health Hazard Symbol Respiratory Sensitizer Germ Cell Mutagenicity
Carcinogenicity
Toxic to Reproduction
STOST (single exposure) – Categories 1-2
STOST (repeated exposure) – Categories 1-2
Aspiration Hazard

27. Environment Symbol
Acute hazards to the aquatic environment – Category 1 (Categories 2 and 3 no symbol or signal word)
Chronic hazards to the aquatic environment – Categories 1 and 2 (Categories 3 and 4 no symbol or signal word)

28. Multiple Hazards
Use all symbols except (different in different GHS adoptions):
OSHA precedence
If skull and crossbones, no exclamation point for acute toxicity
If corrosive, no exclamation point for eye/skin irritation
If health hazard for respiratory sensitization, no exclamation point for skin sensitization or eye/skin irritation

29. Hazard Statements
Hazard statement for each level of hazard (category) within each hazard class (See Appendix C)
Example: Flammable liquids
Category 1: Extremely flammable liquid and vapour
Category 2: Highly flammable liquid and vapour
Category 3: Flammable liquid and vapour
Category 4: Combustible liquid 29 29

30. Hazard Statement Text
The text of all applicable hazard statements shall appear on the label.
Hazard statements may be combined where appropriate to reduce the information on the label and improve readability, as long as all of the hazards are conveyed as required. 30

31. Precautionary Statements
"Precautionary statement" means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling. 31
PDC 408 GHS 2012

32. OSHA Precautionary Statements
There are 4 types of precautionary statements
Prevention
Response
Storage
Disposal 32

33. OSHA Precautionary Statements
Precautionary statements may be combined or consolidated to save label space and improve readability.
Where a chemical is classified for a number of hazards, and the precautionary statements are similar, the most stringent shall be included on the label
An order of precedence may be imposed
If the chemical manufacturer, importer, or responsible party can demonstrate that a precautionary statement is inappropriate to a specific substance or mixture, the precautionary statement may be omitted from the label. 33

34. Supplementary Hazard Information
Limited to when it provides further detail and does not contradict or cast doubt on the validity of the standardized hazard information
Placement shall not impede identification of information required by the Standard. 34

35. Label Arrangement
Label elements located together on the label, tag or mark
Must not conflict with DOT regulations
Pictograms must have red border.
Red frame must be wide enough to be clearly visible
Blank red diamonds are not permitted
Where a DOT label appears on a shipped container, the same OSHA pictogram shall not appear.
Labels must be in English (other languages also permitted)

36. Product identifier 4. Hazard statement(s)
Example of label showing the required elements.
Pictograms are for flammability, acute toxicity, health hazard, and corrosivity.
Product identifier 4. Hazard statement(s)
Signal word 5. Precautionary statement(s)
Pictogram(s) 6. Contact info for responsible party

37. Workplace Labeling HAZARD HMIS/NFPA Category Hazard 1 highest 2 high
Will you continue to use HMIS or NFPA?
While the hazard category number does not appear on the label, consider:
HAZARD
Category Hazard
1 highest
2 high
3 medium
4 low
HMIS/NFPA
Index Hazard
1 slight
2 moderate
3 serious
4 severe

38. What else changed in the Haz Com standard?
MATERIAL SAFETY DATA SHEETS
SAFETY DATA SHEETS

39. What else changed in the Haz Com standard?
Safety Data Sheets
16-section format now required, similar to the current ANSI format.
Order of the sections is specified.
Specific required information for each section is in mandatory Appendix D.
Environmental provisions are included to be GHS- compliant; OSHA will not enforce (sections 12-15).
SAFETY DATA SHEETS
12 – Ecological information
13 – Disposal considerations
14 – Transport information
15 – Regulatory information

40. SDS
Chemical manufacturers and importers shall obtain or develop a safety data sheet for each hazardous chemical they produce or import.
Employers shall have a safety data sheet in the workplace for each hazardous chemical which they use.
Must be in English (additional languages permitted)
No relevant information for a sub-heading, must be marked to indicate no data
Preparer must assure information accurately reflects the scientific evidence used in making hazard classification
Update within 3 months of significant new information. If not currently produces – before shipped again / introduces into the workplace

41. Manufacture SDS Distribution
Provide with initial shipment and with first shipment after update
Either before or with the shipment On request
Retail and wholesale distributors shall post a sign or inform employers that SDS are available

42. New SDS elements
Standardized pictograms, hazard statements, signal words, and precautionary statements.
Exact percentages of ingredients are required in most cases; some may still give ranges.
Conditions to avoid and hazardous decomposition products have been in the ANSI standard for several years.
Percentage ranges are allowed when:
-- there is a trade secret claim.
-- when there is batch-to-batch variability in a product.
-- for a group of substantially similar mixtures with similar chemical composition.

43. 16 Sections
1. Identification 2. Hazard(s) identification 3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling and storage 8. Exposure control/ 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

44. Section 1 Identification
Product identifier used on the label or other means of identification;
Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party;
Emergency phone number

45. Section 2 Hazard(s) Identification
Classification of the chemical
Signal word, hazard statement(s), symbol(s) and precautionary statement(s). (Hazard symbols may be provided as graphical reproductions in black and white or the name of the symbol, e.g., flame, skull and crossbones);

46. Section 3 Composition / Information on Ingredients
For Substances
Chemical name; (b) Common name and synonyms; (c) CAS number and other unique identifiers; (d) Impurities and stabilizing additives which are classified and contribute to the classification of the substance.
For Mixtures In addition to the information required for substances:
The chemical name and concentration (exact percentage) or concentration ranges of all ingredients which are classified as health hazards and         (1) are present above their cut-off/concentration limits; or         (2) present a health risk below the cut-off/concentration limits.
(b) The concentration (exact percentage) shall be specified unless a trade secret claim is made, when there is batch variability or SDS covers similar mixture (these can show ranges).
If trade secret is claimed, a statement that the specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a trade secret is required.

47. Section 4 First-Aid Measures
(a) Description of necessary measures, subdivided according to the different routes of exposure, i.e., inhalation, skin and eye contact, and ingestion; (b) Most important symptoms/effects, acute and delayed. (c) Indication of immediate medical attention and special treatment needed, if necessary.
Section 2 - Classification must be indicated
Section 3 - Changes from the current OSHA limits. 47
PDC 408 GHS 2012

48. Section 5 Fire-Fighting Measures
(a) Suitable (and unsuitable) extinguishing media. (b) Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products). (c) Special protective equipment and precautions for fire-fighters. 48
PDC 408 GHS 2012

49. Section 6 Accidental Release Measures
Personal precautions, protective equipment, and emergency procedures.
(b) Methods and materials for containment and cleaning up.

50. Section 7 Handling and Storage
Precautions for safe handling.
(b) Conditions for safe storage, including any incompatibilities.

51. Section 8 Exposure Controls/Personal Protection
(a) OSHA permissible exposure limit (PEL), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available. (b) Appropriate engineering controls. (c) Individual protection measures, such as personal protective equipment.

52. Section 9 Physical and Chemical Properties
(a) Appearance (physical state, color, etc.); (b) Odor; (c) Odor threshold; (d) pH; (e) Melting point/freezing point; (f) Initial boiling point and boiling range; (g) Flash point; (h) Evaporation rate; (i) Flammability (solid, gas);
(j) Upper/lower flammability or explosive limits; (k) Vapor pressure; (l) Vapor density; (m) Relative density; (n) Solubility(ies); (o) Partition coefficient: n-octanol/water; (p) Auto-ignition temperature; (q) Decomposition temperature; (r) Viscosity.

53. Section 10 Stability and Reactivity
(a) Reactivity; (b) Chemical stability; (c) Possibility of hazardous reactions; (d) Conditions to avoid (e.g., static discharge, shock, or vibration); (e) Incompatible materials; (f) Hazardous decomposition products.

54. Section 11 Toxicological Information
Description of the various toxicological (health) effects and the available data used to identify those effects, including:
Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact);
Symptoms related to the physical, chemical and toxicological characteristics;
Delayed and immediate effects and also chronic effects from short- and long-term exposure;

55. Section 12 Ecological Information
Non-Mandatory
Ecotoxicity (aquatic and terrestrial, where available);
Persistence and degradability;
Bioaccumulative potential;
Mobility in soil;
Other adverse effects (such as hazardous to the ozone layer).

56. Section 13 Disposal Considerations
Non-Mandatory Description of waste residues and information on their safe handling and methods of disposal, including the disposal of any contaminated packaging.

57. Section 14 Transport Information
Non-Mandatory
UN number; UN proper shipping name; Transport hazard class(es); Packing group, if applicable; Environmental hazards (e.g., Marine pollutant (Yes/No)); Special precautions which a user needs to be aware of, or needs to comply with, in connection with transport or conveyance either within or outside their premises.

58. Section 15 Regulatory Information
Non-Mandatory
Safety, health and environmental regulations specific for the product in question.

59. Section 16 Other Information
The date of preparation of the SDS or the last change
References

60. Effective Dates
June 1, 2014 – Employers must train employees on new label and SDS formats.
December 1, 2015 – Labels on distributed containers must comply before shipping.
June 1, 2016 – Employers must update in-house labeling as needed, update written haz com program as needed, & train on any newly-identified hazards.

61. GHS will also require changes in other standards
Wording of signs and labels required in many substance-specific standards.
Definitions of flammable and combustible materials in multiple standards.
Affects virtually all standards addressing chemical hazards (including PSM, laboratories, spray finishing, dipping, coating, welding, hazardous waste, emergency response, etc.).
OSHA is proposing to modify a number of other standards (flammable/combustible liquids, PSM, and substance-specific health standards) to be consistent with the modified HCS requirements
Most OSHA substance- specific heath standards require hazard warning signs, usually for regulated areas, and the language required on the signs varies greatly (e.g., Asbestos, 4-Nitrobiphenyl, 13 Carcinogens, Vinyl Chloride, Inorganic Arsenic, Cadmium, Benzene, Coke Oven Emissions, Cotton Dust, DBCP, Acrylonitrile, Formaldehyde, Methylenedianiline, 1,3-Butadiene, Methylene Chloride, and Lead). With the GHS revision, these standards retain the requirements for specific warning language for specific signs; however, OSHA proposed to modify the language to be compatible with GHS and consistent throughout the OSHA standards. Labels for products, mixtures, and raw materials are included in the GHS-modified HCS and are required to be compliant with it. Labels required by the current standards for contaminated clothing, PPE, and waste and debris, which are not addressed in the GHS, are retained, but their language has been changed to be as reflective of GHS terminology as possible

62. Stay tuned . . . The GHS is updated on a two year cycle.
Recent updates have mostly been text clarifications.
Future updates of the Chemical Haz Com Standard may be necessary
Technical updates for minor terminology changes.
Direct Final Rules for text clarification.
Notice and Comment rulemaking for more substantive or controversial updates.

63. What about Labor and Industries?

64. The new DOSH Haz Com standard
Is expected to be identical to the federal version.
Rulemaking process expected to start 12/18/12, with an effective date of 3/3/13.
There will be outreach, consultation, workshops, and videos to assist employers.
June 1, 2014 – Expected deadline for employers to train employees on new label and SDS formats.
Other deadlines will be the same as the federal standard.

65. Current WISHA Chemical Hazard Communication rules will change
WAC Employer Chemical Hazard Communication
WAC MSDS and Label Preparation
Will become new chapter in March 2013:
WAC , Hazard Communication

66. GHS will also require changes in other standards
WAC Flammable and combustible liquids
WAC Spray finishing
WAC PSM
WAC Hazardous Waste Operations
WAC Dipping and Coating Operations
WAC Part I Welding, Cutting, and Brazing
WAC WAC, Part I-1 Asbestos, Tremolite, Anthophyllite, and Actinolite
WAC , Part F Carcinogens
WAC Vinyl Chloride
WAC Arsenic
WAC Lead
WAC Part I-2 Hexavalent Chromium
WAC Cadmium
WAC Benzene
WAC Part O Coke Ovens
WAC Part N Cotton Dust
WAC ,2-Dibromo-3-chloropropane
WAC Acrylonitrile
WAC Ethylene Oxide
WAC Formaldehyde
WAC Methylenedianiline
WAC Butadiene
WAC Methylene chloride
WAC Hazardous Chemicals In Laboratories
WAC Shipbuilding, Ship Repairing and Ship Breaking
OSHA is proposing to modify a number of other standards (flammable/combustible liquids, PSM, and substance-specific health standards) to be consistent with the modified HCS requirements

67.
Where to watch for news of proposed rules
How to get notifications

68.
When new rule is available, it and related resources will be linked here.

69. Other resources

72. DOSH Specialist on GHS: Pam Edwards, Industrial Hygienist, MES
DOSH Technical Services, Tumwater
(360)
Pam Edwards is the best person to contact with questions about the proposed WISHA rules.