Compliance with OSHA’s Hazard Communication Standard 2012 HAZCOM 2012 Judy Davidson – UAW IH Program Manager Jean Carron – GM IH Program Manager Judy Davidson – UAW IH Program Manager Jean Carron – GM IH Program Manager

HazCom 2012 “HazCom Gets a Facelift” (EHS Today, May 2012) “OSHA, on March 26 in the Federal Register, published the final rule to integrate the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) into OSHA’s Hazard Communication (HazCom) standard.” The amended HazCom standard requires:  Chemical manufacturers to classify chemicals according to their health and physical hazards, and supply that information to the users via updated labels and safety data sheets  Employers to adopt the new standard format for labels and safety data sheets (SDS) for all chemicals manufactured or imported in the United States. “HazCom Gets a Facelift” (EHS Today, May 2012) “OSHA, on March 26 in the Federal Register, published the final rule to integrate the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) into OSHA’s Hazard Communication (HazCom) standard.” The amended HazCom standard requires:  Chemical manufacturers to classify chemicals according to their health and physical hazards, and supply that information to the users via updated labels and safety data sheets  Employers to adopt the new standard format for labels and safety data sheets (SDS) for all chemicals manufactured or imported in the United States.

HazCom 2012 Frequently Asked Questions (FAQ)* Q:What is the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals  Developed by the United Nations (UN)  Single system of chemical hazard communication - - GLOBALLY - - criteria used to determine what is toxic, corrosive, explosive or flammable - - are the same in every country  Symbols used on labels denoting the hazards are the same all over the world  Standardized approach to label elements and material safety data sheets (SDS) –Safety data sheets (SDS) and labels are consistent in their format, wording and type of information given. Q:What is the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals  Developed by the United Nations (UN)  Single system of chemical hazard communication - - GLOBALLY - - criteria used to determine what is toxic, corrosive, explosive or flammable - - are the same in every country  Symbols used on labels denoting the hazards are the same all over the world  Standardized approach to label elements and material safety data sheets (SDS) –Safety data sheets (SDS) and labels are consistent in their format, wording and type of information given. *

HazCom 2012 Q:Why did OSHA decide to modify the Hazard Communication Standard to adopt the GHS?  Original 1983 Hazard Communication standard was performance- oriented (allowed chemical manufacturers and importers to provide information on labels and MSDSs in whatever format they chose)... gave workers the “right-to-know” –HazCom 2012 is “prescriptive” – meaning label and safety data sheet format is standardized... this update is designed to give workers the “right-to-understand”  To improve safety & health of workers through more effective communication of chemical hazards  To facilitate recognition and understanding, employers are required to train employees on the new label elements (e.g. signal words, pictograms and hazard statements) and SDS format by Dec. 1, 2013  OSHA estimates that adopting GHS with HazCom 2012 will prevent more than 500 workplace injuries and save 43 lives per year. Q:Why did OSHA decide to modify the Hazard Communication Standard to adopt the GHS?  Original 1983 Hazard Communication standard was performance- oriented (allowed chemical manufacturers and importers to provide information on labels and MSDSs in whatever format they chose)... gave workers the “right-to-know” –HazCom 2012 is “prescriptive” – meaning label and safety data sheet format is standardized... this update is designed to give workers the “right-to-understand”  To improve safety & health of workers through more effective communication of chemical hazards  To facilitate recognition and understanding, employers are required to train employees on the new label elements (e.g. signal words, pictograms and hazard statements) and SDS format by Dec. 1, 2013  OSHA estimates that adopting GHS with HazCom 2012 will prevent more than 500 workplace injuries and save 43 lives per year.

HazCom 2012 Q:What provisions are unchanged in the revised Hazard Communication Standard (HazCom 2012)?  2012 revised HazCom standard is a modification of the existing standard, not a “major” rewrite of the 25+ year HazCom standard  the parts of the standard that did not relate to the Globally Harmonized System (basic framework, scope, and exemptions) remain largely unchanged. Q:What provisions are unchanged in the revised Hazard Communication Standard (HazCom 2012)?  2012 revised HazCom standard is a modification of the existing standard, not a “major” rewrite of the 25+ year HazCom standard  the parts of the standard that did not relate to the Globally Harmonized System (basic framework, scope, and exemptions) remain largely unchanged.

HazCom 2012 Q:What are the major changes to the Hazard Communication Standard (HazCom 2012)? 3 Major areas of change:  Hazard Classification  Labels  Safety Data Sheets Q:What are the major changes to the Hazard Communication Standard (HazCom 2012)? 3 Major areas of change:  Hazard Classification  Labels  Safety Data Sheets

HazCom 2012 Major Changes - #1 Hazard Classification  Definitions of hazards have been changed to provide specific criteria for classification of health and physical hazards - - (chemical manufacturer’s responsibility)  The standardized classification system ensures consistent classification of hazards across all chemical manufacturers  Labels and safety data sheets are more accurate as a result. Major Changes - #1 Hazard Classification  Definitions of hazards have been changed to provide specific criteria for classification of health and physical hazards - - (chemical manufacturer’s responsibility)  The standardized classification system ensures consistent classification of hazards across all chemical manufacturers  Labels and safety data sheets are more accurate as a result.

HazCom 2012 Major Changes – #2 Labels  Chemical manufacturers and importers will be required to provide: –a Label that includes a harmonized “signal word” (Danger or Warning) –a Pictogram - a symbol plus other graphic elements intended to convey hazard information –Hazard statements for each hazard class and category. Major Changes – #2 Labels  Chemical manufacturers and importers will be required to provide: –a Label that includes a harmonized “signal word” (Danger or Warning) –a Pictogram - a symbol plus other graphic elements intended to convey hazard information –Hazard statements for each hazard class and category.

HAZ-COM 2012

HazCom 2012

Major Changes – #2 Labels (continued)  Hazard & Precautionary Statements –Hazard statements describe the hazards associated with a chemical: Highly flammable liquid and vapor May cause liver and kidney damage –Precautionary statements describe recommended measures that should be taken to protect against hazardous exposures, or improper storage or handling of a chemical: Keep container tightly closed Use only non-sparking tools Major Changes – #2 Labels (continued)  Hazard & Precautionary Statements –Hazard statements describe the hazards associated with a chemical: Highly flammable liquid and vapor May cause liver and kidney damage –Precautionary statements describe recommended measures that should be taken to protect against hazardous exposures, or improper storage or handling of a chemical: Keep container tightly closed Use only non-sparking tools

HazCom 2012 Major Changes - #3 Safety Data Sheets  No longer called Material Safety Data Sheets (MSDS), are now Safety Data Sheets (SDS)  Will have a 16-section standardized format with consistent headings in a specified order sequence (similar to the ANSI standard format which is widely used in the U.S. and is familiar). Major Changes - #3 Safety Data Sheets  No longer called Material Safety Data Sheets (MSDS), are now Safety Data Sheets (SDS)  Will have a 16-section standardized format with consistent headings in a specified order sequence (similar to the ANSI standard format which is widely used in the U.S. and is familiar).

HazCom 2012

Q:What is the phase-in period in the revised HazCom standard?  The phase-in period began in March 2012 and will continue until June 1, 2015 during which time - employers are required to be in compliance with either the existing Hazard Communication standard or the new HazCom 2012, or both  OSHA recognizes: –Hazard communication programs will go through a period of time where labels and SDSs under both standards will be present in the workplace. this is acceptable and employers are not required to maintain two sets of labels and SDSs for compliance purposes. Q:What is the phase-in period in the revised HazCom standard?  The phase-in period began in March 2012 and will continue until June 1, 2015 during which time - employers are required to be in compliance with either the existing Hazard Communication standard or the new HazCom 2012, or both  OSHA recognizes: –Hazard communication programs will go through a period of time where labels and SDSs under both standards will be present in the workplace. this is acceptable and employers are not required to maintain two sets of labels and SDSs for compliance purposes.

HazCom 2012 Q:What is the phase-in period timelines? What you need to do and when:  Chemical users: Continue to use updated safety data sheets when new ones become available, provide training on the new label elements and update hazard communication programs if new hazards are identified.  Chemical producers: Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets. Q:What is the phase-in period timelines? What you need to do and when:  Chemical users: Continue to use updated safety data sheets when new ones become available, provide training on the new label elements and update hazard communication programs if new hazards are identified.  Chemical producers: Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets.

HazCom 2012 Q:Why must training be conducted prior to the compliance effective date?  OSHA is requiring that employees are trained on the new label elements (e.g. pictograms and signal words) and SDS format by Dec. 1, 2013  American workers may have already begun to see HazCom 2012 compliant labels and SDSs shortly after publication of the final rule in March Its’ important to ensure that when employees begin to see new labels and SDSs in the workplace they will be familiar and understand how to use them and access the information effectively  Training is essential to an effective hazard communication approach. The revised HazCom 2012 requires that ALL workers be re-trained by Dec. 1, 2013 to facilitate recognition and understanding of the new labels and safety data sheets  FULL compliance with the final rule will begin in 2015  Compliance must be completed by Dec. 1, Q:Why must training be conducted prior to the compliance effective date?  OSHA is requiring that employees are trained on the new label elements (e.g. pictograms and signal words) and SDS format by Dec. 1, 2013  American workers may have already begun to see HazCom 2012 compliant labels and SDSs shortly after publication of the final rule in March Its’ important to ensure that when employees begin to see new labels and SDSs in the workplace they will be familiar and understand how to use them and access the information effectively  Training is essential to an effective hazard communication approach. The revised HazCom 2012 requires that ALL workers be re-trained by Dec. 1, 2013 to facilitate recognition and understanding of the new labels and safety data sheets  FULL compliance with the final rule will begin in 2015  Compliance must be completed by Dec. 1, 2016.

HazCom 2012 Next Steps……  LJHSC will provide this high level HazCom 2012 update to the PSRB and local HMCC  This presentation is available on the CHR JAS website  Training materials addressing new label elements and SDS format changes are being developed for the Dec. 1, 2013 deadline and will be provided to all U.S. sites  ALL employees must receive training Next Steps……  LJHSC will provide this high level HazCom 2012 update to the PSRB and local HMCC  This presentation is available on the CHR JAS website  Training materials addressing new label elements and SDS format changes are being developed for the Dec. 1, 2013 deadline and will be provided to all U.S. sites  ALL employees must receive training JD:JC:cf/opeiu459aflcio