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NW HELP Group Meeting - August 14, 2013 Presented by Chris Antony, EH&SO IDRI, Seattle, Washington 08/09/2013 ©2013 NW HELP Group: Permission to use granted.

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Presentation on theme: "NW HELP Group Meeting - August 14, 2013 Presented by Chris Antony, EH&SO IDRI, Seattle, Washington 08/09/2013 ©2013 NW HELP Group: Permission to use granted."— Presentation transcript:

1 NW HELP Group Meeting - August 14, 2013 Presented by Chris Antony, EH&SO IDRI, Seattle, Washington 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown 1

2 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown2

3  Closed Course : Professional Drivers Only ◦ “Explanations create comprehension but plans create action” ◦ BUT – If I miss it, get it wrong, or don’t hit the goal – please say something  This presentation is distilled from a number of sources; ◦ An excellent 08/01/13 presentation by Denise Deeds, CIH, at UW’s NW Center for Occupational Health and Safety ◦ Information from Pamela Edwards, IH, with WA L&I, DOSH ◦ UN Publication on GHS 5 th revised edition ◦ Websites for OHSA, NIOSH, WISHA, CDC/NIH ◦ Very good SDS vs MSDS Presentation by staff at JK, Inc., Houston ◦ GHS Implementation Course, National Safety Council ◦ Additional resources listed under Toolkit 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown3

4 Not Covering  How to ‘assemble’ an SDS  Non-Lab GHS implementation  GHS impacts to other Regs  DOT issues  A bunch of other stuff Covering  UN GHS Development  GHS Implementation in US  Brief Recap of /1450  WA State Implementation  Detailed Review of GHS parts ◦ Labels ◦ Pictograms & Hazard revisions ◦ SDS sections  Suggested Action Plan  Ongoing Issues  Toolkit & Resources  Membership in WSACL 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown4

5  ILO Convention on Safety in the Use of Chemicals at Work  Rio “Earth Summit” established 6 program areas on sound management of chemicals - including harmonization of classification and labeling of chemicals  IOMC (Interorganization Programme for the Sound Management of Chemicals) The Coordinating Group for the Harmonization of Chemical Classification Systems led the effort. Technical Work: ◦ Physical Hazards - UN Experts on TDG ◦ Health/Environmental Hazards - OECD ◦ Hazard Communication – ILO  OHSA implements new HSC  UN Adopted Basic GHS components and published “Purple Book” in December 2002, ◦ Rev 1: 2005, Rev 2: 2007, Rev 3: 2009, Rev 4: 2011 ◦ Rev 5: 2013 [see toolkit] 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown5

6  CPSC (Consumer Labeling) changes are under consideration/development  EPA (Pesticides) – 2004 White Paper, 10/06 stakeholder meetings, pursuing voluntary pilot activities, working on interagency coordination. 4/9/12 issued PR Notice Guidance on how to comply with OSHA and EPA re: SDS  DOT adopted changes to regulations to implement the GHS in the transport sector and remain harmonized with the UN TDG – except DOT permits but does not require aquatic toxicity classification: retains the current system  OSHA’s Approach maintains the basic requirements of the current standard  Only change those provisions such as HazCom that need to be changed to adopt the GHS  “Right to Know” becomes “Right to Understand”  Maintain or enhance the level of protection provided by the HCS [thus 2012 rev] looking at scope of chemicals, hazards, information availability and workplace requirements  Allow exemptions to GHS labeling requirement [list in toolkit] including Haz Waste, Bio hazards (infectious only), Radiation (ionizing and non-ionizing), Consumer products only if used in consumer manner (e.g. Bleach) 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown6

7 OHSA - Hazard Communication Standard 2012 [Verbatim text]  (a) Purpose.  (a)(1) The purpose of this section is to ensure that the hazards of all chemicals produced or imported are classified, and that information concerning the classified hazards is transmitted to employers and employees. The requirements of this section are intended to be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 3. The transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, safety data sheets and employee training. OHSA - Hazard Communication Standard 2012 [CTTC text] 1. Ensure chemical hazards are classified 2. Transmit this info to employees via ◦ Container labels – Pictograms! ◦ Safety Data Sheets ◦ Training 3. All info to be consistent with GHS 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown7 Lab specific Regs are

8 Post-GHS ‘Right to Understand” Hazard Classification A Chemical Hygiene Officer who is GHS Trained A Chemical Hygiene Plan with GHS items added Understanding Pictograms/new hazards Understanding how to read an SDS Document GHS Training Label Chemicals: Decision on showing both GHS & Non-GHS Retain MSDS, Replace with SDS as received, provide access 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown8 Pre-GHS “Right to Know” Hazard Determination A Chemical Hygiene Officer A Written Chemical Hygiene Plan NPFA hazards MSDS knowledge Document Training Label Chemicals in the Lab Used the Manufacturers’ Retain and provide MSDS access

9  Compliance Dates Different ◦ Employers train on GHS labels & SDS  Complete by JUNE 1, 2014 vs 12/1/13 ◦ Manufacturers comply with labeling  Complete by JUNE 1, 2015 ◦ Distributors ship only GHS labels  By DECEMBER 1, 2015 ◦ Employers update HazCom  By JUNE 1, 2016  WA Rulemaking effective ◦ APRIL 15, 2013  Employer HazCom ◦ WAC  New WAC Chapter ◦ Update is ◦ Essentially matches the Federal version ◦ WAC (MSDS) not updated  GHS changes some 25 other WACs 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown9

10 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown10

11 Labels Goal: Understand the Six Parts 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown11

12 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown12

13 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown13 New GHS Labels draw all statements from existing text, listed by hazard class – this table is an example of the process

14 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown14 Our challenge is well illustrated by this table  1 is the new 4  4 is the new 1  “Pink is the new black”

15 Pictograms Goal: Understand the Change to Hazard Classification Represented by Each Pictogram 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown15

16 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown16

17 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown17 Hazard Categories within a Classification are determined by Data

18 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown18 Full definitions of each of the sub categories are in Appendix A

19 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown19

20 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown20 Exploding Bomb says it all! Flame  This is a complex set of hazards that includes high-use materials for labs Gases, Aerosols, Liquids, and Solids

21 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown21 Oxidizing materials  Gas = O 2 and O 3  Liquids = Nitric Acid, Chromic acid, Sodium Hypochlorite  Solids = Chromate, Potassium Permanganate

22 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown22 Will be used in by two different Risk Categories  Chemical/PhysicalRisk = e.g. Corrosive Metals  Health Risk = e.g. Eye Damage

23 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown23 Remember: Category 4 = least hazardous condition

24 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown24 Environment Pictogram: “Dead Tree Dead Fish”  No current standard for non-aquatic species e.g. Bees  If it is a category 3 or 4 Environment = no symbol no signal word

25 Safety Data Sheets Goal: Understand the Section changes and where to look for needed data 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown25

26 SAFETY DATA SHEET SECTIONS Section 1. Identification Section 2. Hazard(s) identification Section 3. Composition/information on ingredients Section 4. First-Aid measures Section 5. Fire-fighting measures Section 6. Accidental release measures Section 7. Handling and storage Section 8. Exposure controls/personal protection Section 9. Physical and chemical properties Section 10. Stability and reactivity Section 11. Toxicological information Section 12. Ecological information Section 13. Disposal considerations Section 14. Transport information Section 15. Regulatory information Section 16. Other information, including date of preparation or last revision 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown26

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28 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown28

29 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown29

30 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown30

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32  A revised 2012 OHSA Hazard Communication Standard incorporates a UN based Global Harmonization System for chemical labeling and handling – WA State Adopts  New GHS Labels have 6 parts  Pictograms represent 9 hazard classifications distributed among three hazard groups: one used in two different groups  A 16 section Safety Data Sheet replaces the MSDS 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown32

33  Lab Chem db’s need “agreed to” identifier: IDRI uses CAS ◦ No standard identifer agreed-to at this point – what about mixtures?  Further GHS impacts to Lab operations may occur as WA’s State/Local Agencies adjust to GHS ◦ Adjustment of APP, BECP, or other regs. ◦ Fire Dept Regs - Future impact on SFD HMIS classification (2009 fire code)  SDS Conversion by Chemical vendors has a long way to go ◦ Informal survey of IDRI suppliers shows a broad range of progress  UN Two YR GHS Update process will cause additional changes ◦ e.g. Combustible dusts [un-defined] now specifically addressed – change? ◦ Status of Environmental hazards and implementation 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown33

34  By Sept 2 ◦ “Dig out” your written Hazard Communication Standard (whether it’s or 1450) and review it – then decide if you will hold GHS training in 2013 or 2014 THEN set the date! (IDRI will be Training 10/22-26/13) ◦ You can’t train on subjects that you don’t understand so honestly spend a couple of hours reviewing the hazard classification changes – you’ll get everything else ◦ Determine how you will handle incoming new SDS’s within current system & retain copies of ‘old’ MSDS.  By Sept 30 ◦ CRITICAL – don’t wait to create GHS training materials even if you elect to do the training in first half of 2014 – You’ll run out of time! This training should be KSS = Labels/Picto & Haz Class/SDS.  By Nov 30 ◦ Identify other GHS impacts to your organization [i.e. writing of in-house SDS’s] ◦ Think about being on a Beach in San Diego 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown34

35 1. A Detailed summary recap of Hazard Classifications by Pictogram  Haz Class Summary Deeds.pdf  Appendix A Detailed Hazard Classifications.pdf 2. Direct comparison of OSHA’s HCS 1994 v 2012  https://www.osha.gov/dsg/hazcom/side-by-side.htmlhttps://www.osha.gov/dsg/hazcom/side-by-side.html 3. UN Purple Book 5 th Edition in pdf form 4. Comparison of SDS new Format vs MSDS  MSDSvsSDS_McKelvey_Aug Detailed Guidance for Writing an SDS  GHS Presentation UW [Work by Denese Deeds] 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown35

36 Don’t be a Member of WSACL Washington State Amateur Crastinator League  Turning Pro Right After This GHS Presentation! 08/09/2013 ©2013 NW HELP Group: Permission to use granted provided attribution is shown36


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