March 20, 2012 US Department of Labor's OSHA revises Hazard Communication Standard Regulation protects workers from dangerous chemicals, helps American businesses compete worldwide WASHINGTON – To better protect workers from hazardous chemicals, the U.S. Department of Labor's Occupational Safety and Health Administration has revised its Hazard Communication Standard, aligning it with the United Nations' global chemical labeling system. The new standard, once implemented, will prevent an estimated 43 deaths and result in an estimated $475.2 million in enhanced productivity for U.S. businesses each year. "Exposure to hazardous chemicals is one of the most serious dangers facing American workers today," said Secretary of Labor Hilda L. Solis. "Revising OSHA's Hazard Communication Standard will improve the quality, consistency and clarity of hazard information that workers receive, making it safer for workers to do their jobs and easier for employers to stay competitive in the global marketplace." The Hazard Communication Standard, being revised to align with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals, will be fully implemented in 2016 and benefit workers by reducing confusion about chemical hazards in the workplace, facilitating safety training and improving understanding of hazards, especially for low literacy workers. OSHA's standard will classify chemicals according to their health and physical hazards, and establish consistent labels and safety data sheets for all chemicals made in the United States and imported from abroad. The revised standard also is expected to prevent an estimated 585 injuries and illnesses annually. It will reduce trade barriers and result in estimated annualized benefits in productivity improvements for American businesses that regularly handle, store and use hazardous chemicals, as well as cost savings of $32.2 million for American businesses that periodically update safety data sheets and labels for chemicals covered under the standard. "OSHA's 1983 Hazard Communication Standard gave workers the right to know. As one participant expressed during our rulemaking process, this update will give them the right to understand, as well," said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. During the transition period to the effective completion dates noted in the standard, chemical manufacturers, importers, distributors and employers may comply with either 29 Code of Federal Regulations 1910.1200 (the final standard), the current standard or both. The final rule revising the standard is available at http://s.dol.gov/P1*. Further information for workers, employers and downstream users of hazardous chemicals can be reviewed at OSHA's Hazard Communication Safety and Health topics at http://www.osha.gov/dsg/hazcom/index.html, which includes links to OSHA's revised Hazard Communication Standard and guidance materials such as Q and A's, OSHA fact sheet and Quick Cards. Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA's role is to ensure these conditions for America's working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit http://www.osha.gov.http://s.dol.gov/P1 http://www.osha.gov/dsg/hazcom/index.htmlhttp://www.osha.gov
Global Harmonization Adopted 4-26-2012 New MSDS (New name SDS Safety Data Sheet. 1. Standardized format and information 2. 16 Sections 3. Pictograph use and ease of interpretation so it can be used worldwide. New labels (2), using pictographs, signal words and hazard statement. Primarily affects companies that make MSDS.
Global Benefits of Harmonization – Countries, international organizations, chemical producers and users of chemicals all benefit. Enhance protection of humans and environment. Facilitate international trade in chemicals. Reduce need for testing and evaluation. Assist countries and international organizations to ensure the sound management of chemicals.
Effective Completion DateRequirement(s)Who December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format. Employers June 1, 2015* December 1, 2015 Compliance with all modified provisions of this final rule, except: 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 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 Transition Period to the effective completion dates noted above May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both Chemical manufacturers, importers, distributors, and employers Effective Dates
Chemical Classification Test method neutral Tiered approach for MIXTURE classification – Classify based on data for actual mixture – If data unavail use bridging to estimate based on ingredient information GHS classifies based on both Physical and Health Hazards… Environmental Hazards are also classified and labeled.
Hazards of Chemicals… There are 2 basic types of chemical hazards – Physical Hazards – Health Hazards As well as Environmental Hazards The first rule of Chemical safety is… "Know what you are working with and how to protect yourself and others“
Chemicals can enter the body through: your lungs if you breath fumes, mists or dust your skin if liquid or dust touches or spills on you or splashes in your eyes your mouth if you eat after handling chemicals accidental swallowing of a chemical
HCS Physical Hazards… Chemicals are classified as having Physical Hazards if they are Explosive Compressed Gas Combustible Liquids Flammable Unstable Water Reactive Oxidizers
GHS Physical Hazards Explosives Flammable aerosols Gasses under pressure Self reactive substances Pyrophoric liquids Self heating substances Organic peroxides Substances which on water contact give flammable gasses Oxidizing solids Flammable gasses Oxidizing gases Flammable liquids Flammable solids Pyrophoric solids Oxidizing liquids Corrosive to metals
Chemicals with Physical Hazards… Used only by trained employees Stored in a safe manner Never mixed with other chemicals unless by an approved procedure
HCS Health Hazards Chemicals are classified as being a health hazard if they: Can cause cancer Are poisonous (toxic) Cause harm to your skin, internal organs, or nervous system Are corrosive - such as acids Cause allergic reactions after repeated exposure
Health Effects… Some chemicals affect specific organs such as your kidneys, liver, reproductive or nervous system. THESE ORGANS ARE CALLED TARGET ORGANS…
GHS Health Hazards Acute toxicity (LD50’s and LC 50’s) Skin corrosion/ irritation Serious eye damage/ eye irritation Respiratory and skin sensitizer Germ cell mutagenicity Reproductive toxicity Carcinogenicity Specific target organ toxicity (STOT) single exposure Specific target organ toxicity (STOT) repeated exposure Aspiration hazard
Labeling Comparison OSHA Requirements Must contain: - identity of hazardous chemicals, - name/ address of responsible party, - appropriate hazard warnings. Exposure calculations not permitted in determining whether a hazard must appear on a label. If there is potential for exposure, (other than in minute, trace or very small quantities), the hazard must be included when well-substantiated 1. GHS Requirements Must contain: - product identifier, - name, address, telephone of responsible party - chemical identity - hazard pictograms, signal words, hazard statement, and precautionary information (precautionary information is not standardized yet). For labels, Hazard symbols, signal words, and hazard statements standardized assigned to each hazard category These standardized elements should not be subject to variation, and should appear on the GHS label.
Labeling Comparison OSHA Label Verbiage - No requirements for specific text if appropriate hazard warnings included. permits graphics: pictures, symbols, or combination thereof on a label or other appropriate form which convey the specific physical or health hazard(s), including target organ effects, of the chemical(s) in the container(s) Hazards are considered for exposures under normal conditions of use or in foreseeable emergencies. GHS Label Verbiage Each hazard has a category, or set of categories, with corresponding pictograms, signal words, hazard and precautionary statements. Displays all the hazard statements associated with the product/chemical. “May be harmful if inhaled” is an example of a hazard warning. Provides guidance on using precautionary statements.
Labeling Comparison OSHA Signal Words American National Standards Institute's (ANSI) Standard Z129.1 provides much useful information for employers regarding product labels and is generally very helpful in complying with the HCS. ANSI recommends Caution, Warning, and Danger, in order of increasing severity. Chronic Health Effects Labeling Well substantiated chronic health hazards - for example, carcinogenicity, reproductive toxicity, or developmental toxicity – as well as target organ effects must be stated on the label. Guidance ANSI Z129.1 standard, adherence is not required by law GHS Signal Words GHS uses Warning and Danger only. Comprehensibility The aim of harmonized system is to present information in a manner audience can easily understand. Chronic Health Effects Labeling GHS has classification criteria for chronic health endpoints and standard statements for those hazard categories. "May cause damage to the liver through prolonged or repeated exposure by inhalation” is an example of a standard chronic health effect statement. Guidance GHS is labeling requirement for those countries/regions which adopt the GHS.
In House Labels Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms.
Uniform Labels… Pictures may be used to identify hazards and required protection This Information may also be on the Manufacturer’s label