Australia - Harmful Canada - Toxic China - Non Hazardous EU - Harmful India - Non Toxic Japan - Toxic Malaysia - Harmful New Zealand - Hazardous CAFFEINE (CAS#: 58-08-2) …not coffee ;-)
MOST RECENT DEVELOPMENTS On Monday, March 26th, 2012 OSHA’s final rule addressing U.S. alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) was published in the Federal Register. GHS
VALUABLE TOOL FOR ENABLING GLOBAL TRADE ENHANCES UNDERSTANDING OF HAZARDS FROM FOREIGN PRODUCTS UNIFORM EMPLOYEE TRAINING HELPS COUNTRIES WITH FEW EHS RESOURCES TO COMPETE GLOBALLY WHY?
STATED AT THE AT THE 1992 UNITED NATIONS CONFERENCE ON ENVIRONMENT AND DEVELOPMENT (UNCED) Agenda 21, para.19.27: HISTORY “A globally harmonized classification system and compatible labeling system, including material safety data sheets and easily understandable symbols, should be available, if feasible by the year 2000”
HAZARD COMMUNICATION 29 CFR 1910.1200 “RIGHT TO KNOW” STANDARD “A GREAT STEP FORWARD” WE HAVE COME A LONG WAY FROM 1994
BASIC FRAMEWORK OF THE HCS WILL NOT CHANGE Chemical manufacturers and importers are responsible for providing information about the identities and hazards of chemicals they produce or import All employers using hazardous chemicals within their operations are still required to have a hazard communication program, providing information to employees about chemical hazards and associated protective measures. OSHA - HCS CHANGES
OSHA PELs (and other OELs) required to be listed on SDS Employee re-training required within 2 years of publication of final rule Full compliance required within 3 years of effective date Several other details are being debated OSHA - HCS KEY ELEMENTS
(a) 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 HCS ORGANIZATION
OBJECTIVES The GHS is intended to: Create an internationally recognizable hazard communication system Establish a framework for countries that do not have a hazard communication system Support the trade of chemicals that have been properly assessed and identified for international exchange TODAY
OBJECTIVES The GHS comprises standards for: Classifying chemicals Creates symbols (pictograms) for hazards Creates labeling requirements Establishes a universal MSDS (SDS) WHAT IS IN IT?
GHS classifies materials based on physical and health hazards. Some physical hazard classes include: Explosives Flammable aerosols Flammable gases Flammable liquids Flammable solids Gases under pressure Oxidizing gases……etc. CLASSIFICATION
GHS health hazard classes include: Acute toxicity (LD 50 and LC 50 ) Skin corrosion/irritation Serious eye damage/eye irritation Respiratory and skin sensitization Germ cell mutagenicity Reproductive toxicity Carcinogenicity Specific target organ toxicity (STOT) Aspiration hazard CLASSIFICATION
SIMILAR TO CURRENT EU SYMBOLS Pictograms convey information as one of 3 main groups: Health, Physical and/or Environmental hazards GHS LABELS: PICTOGRAMS
WHITE BACKGROUND GHS LABELS: PICTOGRAMS RED BORDER BLACK SYMBOL
FORMAT Two pictograms are completely new, and are not similar to any current EU pictograms. GHS LABELS: PICTOGRAMS
HEALTH HAZARD The “Health Hazard” features an effected human bust. This pictogram indicates carcinogens, mutagens, reproductive toxicity (CMRs), aspiration hazards, respiratory sensitizers and substances which have target organ toxicity. GHS LABELS: PICTOGRAMS
EXCLAMATION MARK Harmful chemicals and irritants are marked with an “Exclamation Mark,” replacing the European saltire. GHS LABELS: PICTOGRAMS
NEW SKULL & CROSSBONES GHS LABELS: PICTOGRAMS NOT REALLY!
FORMAT The GHS does not specify an exact label format. However, it does require certain provisions. CONTAINER LABELS Product identification Supplier identification Symbols (hazard pictograms) Signal words Hazard statements Precautionary information
FORMAT Currently, OSHA allows labeling format flexibility Common practice in the US to follow ANSI Z129.1-2006 Standard for precautionary labeling CONTAINER LABELS
"DANGER" OR "WARNING" Used to emphasize hazards and indicate severity of the hazard. Lower level hazard categories do not use signal words. Only one signal word corresponding to the class of the hazard should be used on a label. GHS LABELS: SIGNAL WORDS
RISK PHRASES assigned to a hazard class and category that describes the hazard. A statement should be included on the label for each GHS hazard when multiple hazards are associated with the product. GHS LABELS: HAZARD STATEMENTS
RISK PHRASE/HAZARD STATEMENT EXAMPLES “Fatal if in contact with skin” “May cause cancer” “Extremely flammable aerosol” GHS LABELS: HAZARD STATEMENTS
PRECAUTIONARY STATEMENTS Provided to minimize or prevent adverse effects. There are four types of precautionary statements covering: prevention; spill and exposure response; storage, and; disposal. GHS LABELS: ADDITIONAL ELEMENTS
SUPPLEMENTAL INFORMATION Supporting information that does not contradict the standardized hazard information GHS LABELS: ADDITIONAL ELEMENTS
SDS IS THE NEW MSDS Material Safety Data Sheets will now be referred to as Safety Data Sheets. The 16-sections format (similar to ISO, EU and ANSI MSDS/SDS requirements) is now standard. SAFETY DATA SHEETS (SDS)
16-SECTION FORMAT INCLUDES: SDS 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
WHEN IS AN SDS REQUIRED?: SDS When a material contains greater than or equal to 1.0% of a component chemical that can cause: acute toxicity; skin corrosion; serious eye damage; germ cell mutagenicity (Cat. 2); reproductive toxicity; specific target organ toxicity (with repeated exposure), and/or; hazardous to the aquatic environment.
WHEN IS AN SDS REQUIRED?: SDS When a material contains greater than or equal to 0.1% of a component chemical that can cause: respiratory or skin sensitization; germ cell mutagenicity (Cat. 1), and/or; carcinogenicity.
MANUFACTURER CONCERNS SDS Authoring, labels, cost, benefits of trade COMPLIANCE EMPLOYER CONCERNS GHS-compliant SDS and secondary container labels, training, and inclusion in your written hazard communication plan.
WORLD PROGRESS Asia Europe Australia North America South America MANUFACTURERS
UNDER GHS ALL SDSs MUST FOLLOW 16-HEADING FORMAT US Suppliers must re-author their MSDSs in the 16-section GHS format ANSI Z400.1-2004 MSDS Standard already reflects 16-heading GHS format MANUFACTURERS
WHY ADOPT GHS? IT IS REQUIRED! More importantly, worker and consumer safety is improved with uniformity by limiting inconsistencies that exist between the varying nations’ hazard communication systems Companies that do not adopt GHS will be at a disadvantage when doing business internationally WHY?
TRAINING December 1, 2013 Train Employees on the New Label Elements and SDS format EMPLOYERS
TRAINING Employers need to be aware of the GHS as chemicals enter the workplace. Employers importing chemicals from countries that are further along in implementing the GHS will need to address training sooner. Workers should understand GHS labels and be familiar with the 16-section SDS. EMPLOYERS
DEPT. OF TRANSPORTATION (DOT) IS “ON BOARD” ENVIRONMENTAL PROTECTION AGENCY (EPA) COMMITTED TO GHS IN 2004 CONSUMER PRODUCT SAFETY COMMISSION (CPSC) IS STILL REVIEWING US GOVT. AGENCIES
Improved knowledge and recognition of chronic health hazards of chemicals. Framework established for movement towards the elimination of CMRs (carcinogenic, mutagenic, reprotoxic substances), and/or their replacement with less hazardous chemicals. OUTCOMES
CONTAINER LABELS AND PICTOGRAMS MSDS IS NOW SDS (AUTHORED IN A 16-SECTION FORMAT) TRAINING HOW GHS EFFECTS YOU
THREE THINGS YOU NEED TO DO: 1.Review your chemical inventory (update your inventory) 2.Get familiar with your MSDS (now SDS) and secondary labeling requirements 3.Stay informed and train your people (http://www.osha.gov/dsg/hazcom/standards.html)http://www.osha.gov/dsg/hazcom/standards.html (http://www.ghskit.com/(http://www.ghskit.com/) HOW GHS EFFECTS YOU
Questions? Transition Plan? Demos? Contact Referral Partner: Mary Scaggs of HCS Inc. 281.296.9599 Mary@HoustonChemSafe.com
THANK YOU from: Houston Chem Safe Inc and our Network of Regulatory Compliance Experts: Online-MSDS by KHA MSDS Management Software Chemical Inventories Workplace Safety & Health Co. Industrial Hygiene Services KMK Regulatory Services MSDS(SDS) Authoring Transition Plans In Partnership With: Houston Chem Safe Inc. A Certified WDBE Materials & Services Supplier Compliance Solutions Products & Services Let’s talk GHS! Are you ready for OSHA HazCom 2012? Contact Mary Scaggs at 281.296.9599 or Mary@HoustonChemSafe.com. Let’s discuss your next steps…schedule your free demo/webinar today…get you your free GHS Kit.
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