1. GHS: The New OSHA Challenge
Presented at
UL Pure Safety User Group
September 19, 2012

2. What is GHS?
Globally Harmonized System of Classification and Labeling of Chemicals
AKA OSHA 2012
Final rule published March 26, 2012
Effective date – May 25, 2012

3. History of GHS 1992 - Rio Conference 2002 – 1ST Purple Book Issued
2005 – OSHA announces decision to adopt GHS principles
2006 – NPRM
2012 – OSHA issues revision to Hazard Communication regulation

4. Other Agency Involvement
Department of Transportation
Continues to harmonize regulations with international regulations
Environmental Protection Agency
Still evaluating GHS for pesticides
Consumer Product Safety Commission (CPSC)
Nothing being done

5. Why is OSHA adopting GHS?
Common approach to classifying and communicating hazards
Improve quality and consistency of information
Harmonized definitions of hazards
Specific requirements for labels
Required format for SDS

6. Status of GHS Implementation
67 countries in have or are in the process of implementing GHS
Implemented or in
EU – Full compliance 2015
Australia, New Zealand
Japan
China – Required 2011
Mexico, Brazil
Canada – Not adopted yet

7. Major Changes
Hazard classification versus risk classification (no longer performance-oriented)
Labels – specific requirements including pictograms
16 Section SDS

8. Organization of the Final Rule
Purpose
b) Scope and Application
c) Definitions
d) Hazard Classification
e) Written Hazard
Communication Program
f) Labels and Other Forms
of Warning
g) Safety Data Sheets
h) Employee Information and Training
i) Trade Secrets
j) Effective Dates
Appendices A–F

9. APPENDICES • Appendix A, Health Hazard Criteria (Mandatory) (NEW)
• Appendix B, Physical Hazard Criteria (Mandatory) (NEW)
• Appendix C, Allocation of Label Elements (Mandatory) (NEW)
• Appendix D, Safety Data Sheets (Mandatory) (NEW)
• Appendix E, Definition of “Trade Secret” (Mandatory)
• Appendix F, Guidance for Hazard Classifications
re: Carcinogenicity (Non-Mandatory) (NEW)

10. SOME NOTABLE CHANGES OSHA 1994 OSHA 2012 Physical hazard – closed list
Health hazard – open list
Defined as chemical causing acute or chronic health effects
OSHA 2012
Health hazard – closed list
Adds combustible dust, simple asphyxiant, pyrophoric gas and not else where classified

11. SOME NOTABLE CHANGES OSHA 1994 OSHA 2012 Performance Oriented
Definitions
Floor of chemicals considered hazardous
One study rule
OSHA 2012
Specification based
Classification vs. determination
Weight of evidence
Detailed criteria for each hazard class

12. SOME NOTABLE CHANGES OSHA 1994 OSHA 2012
Assigns chemical to a hazard class
Nothing to show severity – reliance on other labeling systems such as HMIS and NFPA
OSHA 2012
Hazard type
Assigns chemical to hazard category
Degree of severity

13. SOME NOTABLE CHANGES OSHA 1994 OSHA 2012 Physical Hazard
Flammable and combustible liquids
Oxidizer
OSHA 2012
Physical hazard
Flammable Liquids 1, 2, 3, and 4
Oxidizing Gases 1, Oxidizing Liquids 1,2, and 3, Oxidizing Solids 1, 2, 3

14. SOME NOTABLE CHANGES OSHA 1994 OSHA 2012 Health Hazard Health hazard
Highly toxic, toxic
Corrosives
Irritants
OSHA 2012
Health hazard
Acute toxicity 1, 2, 3, and 4
Skin Corrosion/Irritation 1a, 1b, 1c and 2
Serious eye damage/irritation 1 and 2

15. Mixtures SOME NOTABLE CHANGES OSHA 1994 – Mixtures Tested – Use data
Untested – 1% for hazards except 0.1% for carcinogens

16. Mixtures SOME NOTABLE CHANGES OSHA 2012 –Tiered approach
Use test data if available
Bridging principles
Estimate hazards based on ingredient information
Specific requirements for each hazard class
Does not apply to carcinogens

17. Important Dates
December 1, 2013 – Employers must train employees on new label requirements, pictograms and new SDS format
June 1, 2015 – Chemical manufacturers, importers and distributors and employers must comply with all provisions

18. LABELS OSHA 1994 REQUIRED INFORMATION Identity of hazardous chemical
Appropriate warnings
Name and address of responsible party
Label phrasing developed by manufacturer

19. LABELS OSHA 2012 REQUIRED INFORMATION Product Identifier Signal Word
Hazard Statements
Pictograms
Precautionary statements
Name and address of responsible party

20. LABELS OSHA 2012 Mandatory phrasing Pictograms require a red border
No blank boxes for pictograms
Only Danger and Warning
May have labels that do not contain a signal word
Manufacturer can include other information such as PPE pictograms as well as use information

25. PICTOGRAMS

30. Examples of required phrase
Toxic Material
Danger Fatal if Swallowed
Required skull and crossbones pictograms
Prevention – Wash thoroughly after handling. Do not eat, drink or smoke when using this product
Response – If swallowed, Immediately call poison center/doctor…
Specific treatment – Rinse mouth
Storage and disposal

32. (Material) Safety Data Sheets
Now called Safety Data Sheets
Uses standardized 16 section
OSHA includes Sections but will not enforce those sections
Ecological information
Transportation
Disposal
Regulatory Information

33. Safety Data Sheets Sections 2 and 3 switched
Required data within each section
Can not leave anything blank – put in “no information available”, “not applicable” or “not determined”
Still need to include ACGIH TLV and OSHA TWA values – Required for Section 8
Still need IARC and NTP Info in Section 11

34. Safety Data Sheets
Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.
Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.

35. Safety Data Sheets
Section 4, First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.
Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.
Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup. .

36. Safety Data Sheets
Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.
Section 8, Exposure controls/personal protection lists OSHA's Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
Section 9, Physical and chemical properties lists the chemical's characteristics.

37. Safety Data Sheets
Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.
Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
Section 12, Ecological information*
Section 13, Disposal considerations*
Section 14, Transport information*
Section 15, Regulatory information*
Section 16, Other information, includes the date of preparation or last revision

38. Important Dates
Up to December 1, 2015 – Distributors may ship products previously labeled under old system
June 1, 2016 – Update alternative workplace alternative labeling and hazard communication programs and provide additional training to employees
Transition Period – Comply with OSHA 1994, OSHA 2012 or both

39. COMPLIANCE CHALLENGES
For Quaker
10,000 products will need classified under the new system
Need GHS classification for raw materials
Need GHS-compliant SDS information from raw material suppliers
Changes to labels and SDS
Train employees on new labels, pictograms and SDS format

40. COMPLIANCE CHALLENGES
For Employers
Obtain new SDS from suppliers
Train employees on new labels, pictograms, SDS
Update Hazard Communication program
Update alternative labeling systems if being used
Transition period with both systems will create confusion in the workplace

41. Resources for Additional Information
United Nations
OSHA
Copy of Federal Register

42. Contact Information
Kathryn F. Strang, CHMM
Sr. Advisor – Safety, Health and Environmental