Hazard Communication Training Program (including GHS revisions) Prepared by Consultation Education & Training (CET) Division Michigan Occupational Safety & Health Administration Michigan Department of Licensing and Regulatory Affairs www.michigan.gov/miosha (517) 322-1809 (Revised: 08/23/13) Last revised: 08/23/13 – Jenelle’s updates This training session is designed to provide information to employees who work with hazardous chemicals and substances. Employers are required to provide training to employees by December 1, 2013. 08/16/13: Minor revisions were made associated with the compliance dates listed in the speakers notes on a few slides.

Agenda Supplemental Employee Training (to be provided by employer) Overview of changes to the MIOSHA Part 42, 92 and 430: Hazard Communication Standard (Haz Com) Labeling requirements Safety Data Sheets (SDS) format – 16 sections Supplemental Employee Training (to be provided by employer) This training includes: An overview of the changes to the MIOSHA Haz Com Standard; The new labeling requirements; Information on the new safety data sheets in the 16 section format; and, Details of the facility specific haz com program. This portion of the training program is designed to provide guidance to employers on information they must include in order for the employee training program to be compliant with the MIOSHA Haz Com Standard.

MODULE ONE Overview and Classification

Why the Change to Haz Com? To align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) adopted by 67 nations To provide a common and coherent approach to classifying chemicals Reduce confusion and increase understanding of the hazards Facilitate training Help address literacy problems So, why the change? Since 1992, the United Nations have been working to create and enhance a globally harmonized system for the classification and labeling of chemicals that can be used by importers, distributers and manufacturers worldwide. 2012 Haz Com revised standard is based on GHS revision 3. The goal is to provide a common and coherent approach to classifying chemicals. This will benefit employees as it will: Reduce confusion and increase understanding of the hazards. Facilitate training Help address literacy problems particularly due to use of pictograms

Who is Affected? Manufacturers, Distributors, Importers Employers Change SDS information and format Change container labeling Employers Training employees on changes to: SDS (change from MSDS to SDS and 16-section format) Container Labels (including secondary containers) Employees Recognize and understand hazards based on: Information in new SDS format Pictograms on container labels Precautionary and hazard statements

Other Standards Affected – Health (signage requirements) Asbestos Carcinogens Vinyl Chloride Inorganic Arsenic Lead Cadmium Benzene Coke Oven Emissions Acrylonitrile Ethylene Oxide Formaldehyde Methylenedianiline This slide lists the other MIOSHA standards that are affected by the changes adopted in the 2012 Haz Com. Language on required signs in the listed standards, will be harmonized with Haz Com and GHS. For example the sign for lead will be changed as noted above. Chromium (VI) does not appear to have any changes. Refer to the signage handout (CET-5533) or the GHS page on the MIOSHA website, for additional information on signage requirements. http://www.michigan.gov/documents/lara/lara_miosha_cet5533_402987_7.docx Note: Label requirements for substance specific standards must be completed on or by June 1, 2015. Example: Asbestos pipe wrap (thermal system insulation) label must have be new language and placed by June 1, 2015, but the sign for the regulated area (area under abatement) must be updated by June 1, 2016. DANGER LEAD MAY DAMAGE FERTILITY OR THE UNBORN CHILD CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM DO NOT EAT, DRINK OR SMOKE IN THIS AREA WARNING LEAD WORK AREA POISON NO SMOKING OR EATING New Sign “LEAD”

Other Standards Affected Flammable and Combustible Liquids Spray Finishing using Flammable and Combustible Materials Process Safety Management of Highly Hazardous Chemicals (PSM) Hazardous Waste Operations and Emergency Response (HAZWOPER) Hazardous Work In Laboratories Dipping and Coating Operations Welding, Cutting and Brazing Employee Medical Records and Trade Secrets Here is a list of the other standards affected. In some cases, definitions may have changed in the standards listed above. Chromium (VI) does not appear to have any changes. Refer to the handout CET-5532 or the GHS page on the MIOSHA website, for additional information on the other Standards affected: http://www.michigan.gov/documents/lara/lara_miosha_cet5532_402986_7.doc

Effective Dates and Requirements Effective Completion Date Requirement(s) Responsible Party December 1, 2013 Train employees on the new label elements and SDS format Employers June 1, 2015 Compliance with all modified provisions of the final rule except: Chemical manufacturers, importers, distributors, and employers December 1, 2015 The distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label Distributor June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified hazards [and affected vertical standard specific signage] Employer Transition Period: 12/2012 to the effective completion dates noted above May comply with either MIOSHA Part 42, 92 and 430 (final standard), or the current standard, or both This chart was provided by Federal OSHA with one addition which is noted in brackets. Effective on or by June 1, 2015: - All SDS must be completed and shipped/sent to users with the 1st order shipped on or after June 1, 2015. Employers/users of chemicals review to ensure all SDS received on or after June 1, 2015 are in the new format. Per OSHA, employers are not required to pursue getting new SDSs for products received before June 1, 2015; unless they are aware of changes to the hazards in the product. For older products, material safety data sheets for the products must kept as long as chemical is onsite/use,d then archived as required. - Vertical chemical specific standards with label requirements must be changed to harmonize with 1910.1200 Haz Com. Effective on or by June 1, 2016 - Employer/user must have program updated including any additional training and any label changes completed. - Vertical chemical specific standards with signage requirements will be changing to harmonize with 1910.1200 Haz Com. The added text in brackets reflects this.

Chemical Classifications Chemicals will be classified using a harmonized system that provides standardized language for: Health Hazard Categories Physical Hazard Categories Environmental Hazard Categories* Previously, chemical hazards were evaluated in a more subjective manner. Chemicals must now go through a specific, prescriptive classification process to determine which hazards are present and which hazard and precautionary statements apply. This can be a lengthy process. Environmental Hazards are not regulated by MIOSHA. Check with the Michigan Department of Environmental Quality (DEQ) for any employee training requirements for these sections. DEQ Environmental Assistance Center can be reached at (800) 662-9278 from 8 a.m. to 4:30 p.m., Monday through Friday or email: deq-assist@michigan.gov *Not regulated by MIOSHA.

Chemical Classifications: Health Hazards Acute Toxicity Skin Corrosion/Irritation Respiratory or Skin Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Specific Target Organ Toxicity – Single Exposure Specific Target Organ Toxicity – Repeated Exposure Aspiration Simple Asphyxiants Now there are 10 established chemical health classifications; that are further defined and described in Appendix A of the Haz Com Standard. Appendix A is to be used by manufacturers, importers and distributers to determine if any of their products are classified as a health hazards. If the product is classified as a health hazard in one or more of the 10 health hazard classifications listed on this slide, Appendix A is used to determine the severity of the hazard (or hazard category) under the applicable hazard class. More information noted in the chart on the next slide. Note: Simple Asphyxiants are not part of the current GHS (international standard) but were specifically included by OSHA as a hazard classification under the 2012 Haz Com Standard.

Chemical Classifications: Health Hazards Hazard Class Hazard Category Acute toxicity 1 2 3 4 Skin Corrosion/Irritation 1A 1B 1C Serious Eye Damage/Eye Irritation 2A 2B Respiratory or Skin Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Lactation Specific Target Organ Toxicity – Single Exposure Specific Target Organ Toxicity – Repeated Exposure Aspiration Simple Asphyxiants Single Category This chart shows the new health hazard classes and the hazard categories that correspond to each of the health hazard classes. Hazard category 1 (or column furthest to the left) is the most hazardous. Hazard categories become less severe as you move to the right in the chart. Manufacturers, importers and distributers must classify all hazards for their products.

Chemical Classifications: Physical Hazards Explosives Flammable Aerosols Oxidizing Gases Gases under Pressure Compressed Gases Liquefied Gases Refrigerated Liquefied Gases Dissolves Gases Each of the chemical physical classifications are further defined and described in Appendix B of the Haz Com Standard. Appendix B is to be used by manufacturers, importers and distributers to determine if any of their products are classified as a physical hazard. If the product is classified as a physical hazard in one or more of the physical hazard classifications, Appendix B is used to determine the severity of the hazard (or hazard category).

Chemical Classifications: Physical Hazards (continued) Flammable Liquids Flammable Solids Self-Reactive Chemicals Pyrophoric Liquids Pyrophoric Solid Pyrophoric Gases Self-heating Chemicals Chemicals, which in contact with water, emit flammable gases

Chemical Classifications: Physical Hazards (continued) Oxidizing Liquids Oxidizing Solid Organic Peroxides Corrosive to Metals Combustible Dusts Note: Pyrophoric Gases and Combustible Dust are not part of the GHS (international standard) but were specifically included by OSHA as physical hazard classifications under the 2012 Haz Com Standard.

Chemical Classifications: Physical Hazards Hazard Class Hazard Category Explosives Unstable Explosives Div 1.1 Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6 Flammable Gases 1 2   Flammable Aerosols Oxidizing Gases Gases under Pressure Compressed gases Liquefied gases Refrigerated liquefied gases Dissolved gases Flammable Liquids 3 4 Flammable Solids Self-Reactive Chemicals Type A Type B Type C Type D Type E Type F Type G Pyrophoric Liquids Pyrophoric Solids Pyrophoric Gases Single Category Self-Heating Chemicals Chemicals in which contact with water emit flammable gases Oxidizing Liquids Oxidizing Solids Organic Peroxides Corrosive to Metals Combustible Dust This chart shows the physical hazard classes and the hazard categories that correspond to each of the physical hazard classes. Hazard category 1 (or column furthest to the left) is the most hazardous. Hazard categories become less severe as you move to the right in the chart. Manufacturers, importers and distributers must classify all hazards for their products.

This Concludes Module One