GHS: The New OSHA Challenge Presented at UL Pure Safety User Group September 19, 2012

What is GHS? Globally Harmonized System of Classification and Labeling of Chemicals AKA OSHA 2012 Final rule published March 26, 2012 Effective date – May 25, 2012

History of GHS 1992 - Rio Conference 2002 – 1ST Purple Book Issued 2005 – OSHA announces decision to adopt GHS principles 2006 – NPRM 2012 – OSHA issues revision to Hazard Communication regulation

Other Agency Involvement Department of Transportation Continues to harmonize regulations with international regulations Environmental Protection Agency Still evaluating GHS for pesticides Consumer Product Safety Commission (CPSC) Nothing being done

Why is OSHA adopting GHS? Common approach to classifying and communicating hazards Improve quality and consistency of information Harmonized definitions of hazards Specific requirements for labels Required format for SDS

Status of GHS Implementation 67 countries in have or are in the process of implementing GHS Implemented or in EU – Full compliance 2015 Australia, New Zealand Japan China – Required 2011 Mexico, Brazil Canada – Not adopted yet

Major Changes Hazard classification versus risk classification (no longer performance-oriented) Labels – specific requirements including pictograms 16 Section SDS

Organization of the Final Rule Purpose b) Scope and Application c) Definitions d) Hazard Classification e) Written Hazard Communication Program f) Labels and Other Forms of Warning g) Safety Data Sheets h) Employee Information and Training i) Trade Secrets j) Effective Dates Appendices A–F

APPENDICES • Appendix A, Health Hazard Criteria (Mandatory) (NEW) • Appendix B, Physical Hazard Criteria (Mandatory) (NEW) • Appendix C, Allocation of Label Elements (Mandatory) (NEW) • Appendix D, Safety Data Sheets (Mandatory) (NEW) • Appendix E, Definition of “Trade Secret” (Mandatory) • Appendix F, Guidance for Hazard Classifications re: Carcinogenicity (Non-Mandatory) (NEW)

SOME NOTABLE CHANGES OSHA 1994 OSHA 2012 Physical hazard – closed list Health hazard – open list Defined as chemical causing acute or chronic health effects OSHA 2012 Health hazard – closed list Adds combustible dust, simple asphyxiant, pyrophoric gas and not else where classified

SOME NOTABLE CHANGES OSHA 1994 OSHA 2012 Performance Oriented Definitions Floor of chemicals considered hazardous One study rule OSHA 2012 Specification based Classification vs. determination Weight of evidence Detailed criteria for each hazard class

SOME NOTABLE CHANGES OSHA 1994 OSHA 2012 Assigns chemical to a hazard class Nothing to show severity – reliance on other labeling systems such as HMIS and NFPA OSHA 2012 Hazard type Assigns chemical to hazard category Degree of severity

SOME NOTABLE CHANGES OSHA 1994 OSHA 2012 Physical Hazard Flammable and combustible liquids Oxidizer OSHA 2012 Physical hazard Flammable Liquids 1, 2, 3, and 4 Oxidizing Gases 1, Oxidizing Liquids 1,2, and 3, Oxidizing Solids 1, 2, 3

SOME NOTABLE CHANGES OSHA 1994 OSHA 2012 Health Hazard Health hazard Highly toxic, toxic Corrosives Irritants OSHA 2012 Health hazard Acute toxicity 1, 2, 3, and 4 Skin Corrosion/Irritation 1a, 1b, 1c and 2 Serious eye damage/irritation 1 and 2

Mixtures SOME NOTABLE CHANGES OSHA 1994 – Mixtures Tested – Use data Untested – 1% for hazards except 0.1% for carcinogens

Mixtures SOME NOTABLE CHANGES OSHA 2012 –Tiered approach Use test data if available Bridging principles Estimate hazards based on ingredient information Specific requirements for each hazard class Does not apply to carcinogens

Important Dates December 1, 2013 – Employers must train employees on new label requirements, pictograms and new SDS format June 1, 2015 – Chemical manufacturers, importers and distributors and employers must comply with all provisions

LABELS OSHA 1994 REQUIRED INFORMATION Identity of hazardous chemical Appropriate warnings Name and address of responsible party Label phrasing developed by manufacturer

LABELS OSHA 2012 REQUIRED INFORMATION Product Identifier Signal Word Hazard Statements Pictograms Precautionary statements Name and address of responsible party

LABELS OSHA 2012 Mandatory phrasing Pictograms require a red border No blank boxes for pictograms Only Danger and Warning May have labels that do not contain a signal word Manufacturer can include other information such as PPE pictograms as well as use information

PICTOGRAMS

Examples of required phrase Toxic Material Danger Fatal if Swallowed Required skull and crossbones pictograms Prevention – Wash thoroughly after handling. Do not eat, drink or smoke when using this product Response – If swallowed, Immediately call poison center/doctor… Specific treatment – Rinse mouth Storage and disposal

(Material) Safety Data Sheets Now called Safety Data Sheets Uses standardized 16 section OSHA includes Sections 12-15 but will not enforce those sections Ecological information Transportation Disposal Regulatory Information

Safety Data Sheets Sections 2 and 3 switched Required data within each section Can not leave anything blank – put in “no information available”, “not applicable” or “not determined” Still need to include ACGIH TLV and OSHA TWA values – Required for Section 8 Still need IARC and NTP Info in Section 11

Safety Data Sheets Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use. Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements. Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.

Safety Data Sheets Section 4, First-aid measures includes important symptoms/ effects, acute, delayed; required treatment. Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire. Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup. .

Safety Data Sheets Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities. Section 8, Exposure controls/personal protection lists OSHA's Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE). Section 9, Physical and chemical properties lists the chemical's characteristics.

Safety Data Sheets Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions. Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity. Section 12, Ecological information* Section 13, Disposal considerations* Section 14, Transport information* Section 15, Regulatory information* Section 16, Other information, includes the date of preparation or last revision

Important Dates Up to December 1, 2015 – Distributors may ship products previously labeled under old system June 1, 2016 – Update alternative workplace alternative labeling and hazard communication programs and provide additional training to employees Transition Period – Comply with OSHA 1994, OSHA 2012 or both

COMPLIANCE CHALLENGES For Quaker 10,000 products will need classified under the new system Need GHS classification for raw materials Need GHS-compliant SDS information from raw material suppliers Changes to labels and SDS Train employees on new labels, pictograms and SDS format

COMPLIANCE CHALLENGES For Employers Obtain new SDS from suppliers Train employees on new labels, pictograms, SDS Update Hazard Communication program Update alternative labeling systems if being used Transition period with both systems will create confusion in the workplace

Resources for Additional Information United Nations http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html OSHA http://www.osha.gov/dsg/hazcom/index.html Copy of Federal Register http://www.osha.gov/dsg/hazcom/ghs-final-rule.html

Contact Information Kathryn F. Strang, CHMM Sr. Advisor – Safety, Health and Environmental 610-832-4304 strangk@quakerchem.com