Presentation on theme: "Chemical Hazard Communication Standard"— Presentation transcript:
1 Chemical Hazard Communication Standard Globally Harmonized System of Classification and Labeling of Chemicals WACIntroduce selfIntroduce topicPam Edwards , IH, MSTechnical Service DOSHOlympia , WA
2 Overview What is the Globally Harmonized System? What changed in OSHA’s new Chemical Hazard Communication standard?SDSLabelsWhat 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
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 CPSCThe 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 3Changes toClassificationLabel ContentSafety Data Sheet Content (mandatory 16 section SDS, % required)No Changes toScope and ExemptionsWritten Hazcom ProgramLabeling requirementMSDS Distribution and Availability in the WorkplaceEmployee 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 chemicalsFood, food additives, color additives, drugs, cosmetics, medical/veterinary devices, alcoholic beveragesConsumer 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 wasteHazardous substances at a CERCLA remediation siteTobaccoWood and wood products which will not be processed and only present a fire hazardArticlesFood 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 determinationNow titled “hazard classification”Detailed data-based criteriaHealth hazard criteria in mandatory Appendix A and non-mandatory Appendix FPhysical hazard criteria in mandatory Appendix BSpecified; 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 ClassHazard Category (health hazard criteria, Appendix A)Acute toxicity1234Skin corrosion/irritation1A1B1CSerious eye damage/irritation2A2BRespiratory or skin sensitizersGerm cell mutagenicityCarcinogenicityReproductive toxicitylactationSpecific target organ toxicity - single exposureSpecific target organ toxicity - repeated exposureAspirationThese are the hazard classes and categories for health hazards, from Appendix A.
16 Hazard Category (physical hazard criteria, Appendix B) Explosive Hazard ClassHazard Category (physical hazard criteria, Appendix B)ExplosiveUnstableDiv 1.1Div 1.2 Div 1.3Flammable gases12Flammable aerosolsOxidizing gasesGases under pressureCompressedLiquefiedRefrigerated liquefiedDissolvedFlammable liquids34Flammable solidsSelf-reactiveABCDEFGPyrophoric liquidsPyrophoric solidsSelf-heatingEmits flammable gas when in contact with waterOxidizing liquidsOxidizing solidsOrganic peroxidesCorrosive to metalsThese 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 SolidsSelf-Reactives (Type B with bomb, Types C-F)Pyrophoric liquids and solidsSelf-heating substancesSubstances which in contact with water emit flammable gasesOrganic Peroxides (Type B with bomb, Types C-F)
21 Flame over Circle Symbol Oxidizing GasesOxidizing LiquidsOxidizing Solids
22 Gas Cylinder Symbol Compressed Gas Liquefied Gas Refrigerated Liquefied GasDissolved Gas
23 Corrosion SymbolCorrosive 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 2Serious Eye damage/ irritation – Category 2ASkin SensitizerSTOST (single exposure) – Category 3 (respiratory tract irritation, narcotic effects)Hazardous to the Ozone Layer
26 Health Hazard Symbol Respiratory Sensitizer Germ Cell Mutagenicity CarcinogenicityToxic to ReproductionSTOST (single exposure) – Categories 1-2STOST (repeated exposure) – Categories 1-2Aspiration Hazard
27 Environment SymbolAcute 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 HazardsUse all symbols except (different in different GHS adoptions):OSHA precedenceIf skull and crossbones, no exclamation point for acute toxicityIf corrosive, no exclamation point for eye/skin irritationIf health hazard for respiratory sensitization, no exclamation point for skin sensitization or eye/skin irritation
29 Hazard StatementsHazard statement for each level of hazard (category) within each hazard class (See Appendix C)Example: Flammable liquidsCategory 1: Extremely flammable liquid and vapourCategory 2: Highly flammable liquid and vapourCategory 3: Flammable liquid and vapourCategory 4: Combustible liquid2929
30 Hazard Statement TextThe 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.31PDC 408 GHS 2012
32 OSHA Precautionary Statements There are 4 types of precautionary statementsPreventionResponseStorageDisposal32
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 labelAn order of precedence may be imposedIf 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 informationPlacement shall not impede identification of information required by the Standard.34
35 Label ArrangementLabel elements located together on the label, tag or markMust not conflict with DOT regulationsPictograms must have red border.Red frame must be wide enough to be clearly visibleBlank red diamonds are not permittedWhere 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:HAZARDCategory Hazard1 highest2 high3 medium4 lowHMIS/NFPAIndex Hazard1 slight2 moderate3 serious4 severe
38 What else changed in the Haz Com standard? MATERIAL SAFETY DATA SHEETSSAFETY DATA SHEETS
39 What else changed in the Haz Com standard? Safety Data Sheets16-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 SHEETS12 – Ecological information13 – Disposal considerations14 – Transport information15 – Regulatory information
40 SDSChemical 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 dataPreparer must assure information accurately reflects the scientific evidence used in making hazard classificationUpdate 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 updateEither before or with the shipment On requestRetail and wholesale distributors shall post a sign or inform employers that SDS are available
42 New SDS elementsStandardized 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 Sections1. 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 protection9. 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 chemicalSignal 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 SubstancesChemical 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 indicatedSection 3 - Changes from the current OSHA limits.47PDC 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.48PDC 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.
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-MandatoryEcotoxicity (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-MandatoryUN 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-MandatorySafety, 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 changeReferences
60 Effective DatesJune 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 requirementsMost 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 necessaryTechnical updates for minor terminology changes.Direct Final Rules for text clarification.Notice and Comment rulemaking for more substantive or controversial updates.
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 CommunicationWAC MSDS and Label PreparationWill become new chapter in March 2013:WAC , Hazard Communication
66 GHS will also require changes in other standards WAC Flammable and combustible liquidsWAC Spray finishingWAC PSMWAC Hazardous Waste OperationsWAC Dipping and Coating OperationsWAC Part I Welding, Cutting, and BrazingWAC WAC, Part I-1 Asbestos, Tremolite, Anthophyllite, and ActinoliteWAC , Part F CarcinogensWAC Vinyl ChlorideWAC ArsenicWAC LeadWAC Part I-2 Hexavalent ChromiumWAC CadmiumWAC BenzeneWAC Part O Coke OvensWAC Part N Cotton DustWAC ,2-Dibromo-3-chloropropaneWAC AcrylonitrileWAC Ethylene OxideWAC FormaldehydeWAC MethylenedianilineWAC ButadieneWAC Methylene chlorideWAC Hazardous Chemicals In LaboratoriesWAC Shipbuilding, Ship Repairing and Ship BreakingOSHA 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 rulesHow to get notifications
68 When new rule is available, it and related resources will be linked here.