New GHS / OSHA Requirements January 2014

Contents Introduction What is GHS / OSHA HazCom 2012? What is an SDS? What is a GHS compliant label? GHS Pictograms Timelines for implementation. How does my Company become compliant?

Introduction Requirements for chemical labels are regulated by OSHA in the U.S. and individual countries throughout the world use their own requirements to communicate any hazards to the end user or in the workplace during manufacture. Today, we are in an era of global commerce, where the typical supply chain can span many countries across the world. The United Nations and the International Labor Organization (ILO) has determined that a universally understood communication system is needed to classify and label chemicals in order to convey any hazards and risks to human health to all users. Under this directive, the Globally Harmonized System of classification and labeling of chemicals, otherwise known as GHS, was created.

What is GHS and Hazcom 2012? GHS and OSHA HazCom 2012 is one and the same. OSHA has decided to align its Hazard Communication to the Global Harmonized System (GHS). GHS will require all manufacturers to re-assess each chemical under the new 16 classifications of physical hazards criteria. Transitioning to this new system is a daunting task for any manufacturer and will involve both upstream and downstream supply chain partners. Recognizing the burden this places on manufacturers, a gradual phase in period was implemented, providing a limited grace period. In Europe, this period ended in December of 2012 and all products sold to any European Union countries should be GHS compliant.

What is an SDS? An SDS is simply a “Safety Data Sheet”, more familiarly known to most of us in the United States and Canada as an MSDS (Material Safety Data Sheet). The new SDS format is similar to the familiar MSDS, but has 16 sections in a specific order, and also includes information on Ecological impact, Disposal considerations, Transport and regulatory information. The SDS must also include GHS pictograms which are diamond shaped symbols, that are in black print on a white background, with red borders. This new regulation will require SDS’s to be printed on a color printer.

GHS labeling requirements Under GHS regulation, there are 6 basic elements that must appear on any chemical label when shipped. These six elements are: Product Identifier – the name of the pure substance or mixture. This product identifier must also be exactly the same on the associated SDS. GHS Pictograms – one or more of 9 different diamond shaped symbols as appropriate to convey information about any hazards or risks associated with the product. (see slides 8 & 9 for detailed descriptions) Signal Words – “Warning” or “Danger” are the only authorized signal words. Hazard Statements – These statements describe the nature and degree of the hazard.

GHS labeling requirements (cont.) Precautionary Statements – Must relate to the GHS pictogram(s) and describe measures that should be taken to minimize or prevent any risks associated with the hazard(s). Example: “Keep away from heat/sparks/open flames/hot surfaces” in relation to a pictogram that shows explosive danger and a hazard statement such as “Heating may cause an explosion” Supplier Information – must include the name, address and telephone number of the manufacturer, supplier or other responsible party. *Not part of the GHS requirement is supplementary information, which can be any other voluntary information that the manufacturer, supplier or responsible party wishes to convey to the user. This is not required by GHS, but any information given must not conflict with GHS standards. Example – “avoid entry into streams or waterways”. Or “Dispose of empty containers responsibly”.

GHS Pictograms & Hazards Exclamation Mark Irritant – skin & eyes Skin sensitizer Acute toxicity Narcotic effect Respiratory tract irritant Hazardous to Ozone layer Health Hazard Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity Flame Flammables Pyrophenics Self heating Emits flammable gas Self -reactive Organic peroxides Skull & Crossbones Acute Toxicity (Fatal or Toxic)

GHS Pictograms & Hazards (cont.) Flame Over Circle Oxidizers Gas Cylinder Gases Under Pressure Corrosion Skin corrosion / burns Eye Damage Corrosive to Metals Exploding Bomb Explosives Self-Reactive Organic Peroxides Environment (not mandatory) Aquatic Toxicity Optional

GHS Timelines December 1 st, 2012 – Employers are responsible to train all employees on GHS formatted labels and SDS’s. Employees must be made aware of new pictograms and their meaning. June 1 st, 2015 – Manufacturers and Suppliers must ship all products with GHS compliant labels and SDS. December 1 st, 2015 – Distributors must ship all products with GHS compliant labels and SDS. Distributors get an additional 6 months grace period to exhaust any stock products that are not GHS compliant.

Ultrachem’s Timeline Ultrachem has achieved many milestones in it’s almost 50 year history and is known throughout the industry as being first in many areas. Our strategy is to be far ahead of the curve in GHS compliance as well. We are currently in the process of re-assessing all materials used to manufacture our products and creating GHS compliant SDS and labels. This process will evolve over the first half of 2014 and you may begin to see products delivered with GHS complaint labels very soon. Our goal is to have fully GHS compliant labels on all shipments by the end of SDS’s require updated information from our suppliers and many have different timelines to reach full compliance. Because of this situation, GHS compliant SDS’s may take longer to reach Ultrachem and therefore, could create delays for us.

How Does My Company Become Compliant? If Ultrachem designs and supplies your private label package, we will begin working on revising your labeling and packaging for GHS. We will supply drafts of the proposed changes needed to allow your Company to become fully compliant. Remember, when GHS takes effect, it will be against the law for Ultrachem to ship product that does not have GHS compliant labels. If you re-label your own packages at your location, you must also adhere to GHS requirements. OSHA fines are $ per instance. Once fined, if OSHA re-inspects a product that was not compliant a second time, the fine becomes $70,000 per instance. If your Company supplies it’s own labels to Ultrachem, it is your responsibility to make sure the package is GHS compliant before the deadline. After December 1 st, 2015, Ultrachem can not ship any products with non-compliant labels.

Questions ??? New regulations are almost always very daunting and confusing. We’re sure this new regulation will bring many questions and concerns. Rest assured, Ultrachem will help you every step of the way. Speak to your sales professional regarding any questions or reservations you may have about these new requirements. WE’RE HERE TO HELP!! 12/13/13 GDK