Chemical Safety & the New SDS Regulations

Chemical Hazards

Controlling Exposure [SAY] The next few slides introduce exposure control best practices. We have to understand and practice very seriously to protect our body correctly against harm every single time we work with hazardous materials.

Hazard Control Methods Engineering Controls Ventilation, enclosing operations, closed containers, replacement Administrative Controls Training, information, limiting exposure time, policy/procedures Personal Protective Equipment (PPE) Safety goggles, gloves, protective clothing

ENGINEERING CONTROLS Best Practices Dispense products in accordance with the label, safety data sheet, and other product information Use “closed” feed systems where possible Store products in original container when possible Store incompatible materials separately Keep product containers closed when not in use Mix products only in accordance with product instructions Use flammable and volatile chemicals only in well ventilation areas

ADMINISTRATIVE CONTROLS Best Practices Read and follow label and safety data sheet warnings and instructions Post information regarding your hazard communication process and chemicals Properly plan your work to limit chemical exposure time. Inspect containers and feed systems before use Wash hands and face after handling chemicals

PROTECTIVE EQUIPMENT Best Practices Know the location of emergency equipment (eyewash, showers, etc.) Follow SDS regarding personal protective equipment Use goggles and face shields when splash hazards are present Use gloves appropriate for the hazard (check SDS) Gas Monitors

Emergency Actions If exposure occurs: Eye Contact Inhalation Ingestion Flush for 15 minutes Seek medical attention Inhalation Move to fresh air Ingestion Consult SDS Skin Contact Remove contaminated clothing Rinse skin for a minimum of 15 minutes

Chemical Hazard Communication

Objectives Basics of Chemical Hazard Communication Responsibilities Chemical Hazard Concepts Container Labeling Safety Data Sheets Controlling Exposure

What is Hazard Communication? Hazard Communication is a process that helps you understand and control the hazards of chemicals in your work environment. You have a legal “Right-to-Know” about the hazards of the chemicals you work with. Regulations establishing this have been in place for decades.

Manufacturer, Importer, Distributor A Shared Process Manufacturer, Importer, Distributor Employer Employees Contractors [SAY] Here you can see how hazard communication is a shared function involving many groups. All these groups play a very important role in the chemical hazard communication process. This will be discussed in greater detail in the Responsibilities Section. [Point out the Ecolab is both a manufacturer of chemicals and an Employer.]

Responsibilities [SAY] The next few slides introduce exposure control best practices. We have to understand and practice very seriously to protect our body correctly against harm every single time we work with hazardous materials.

Manufacturer Responsibilities Manufacturer, Importer, Distributor Employer Employees Contractors Evaluate hazards of the products they produce or import. Provide information such as product labels and safety data sheets. [SAY] Manufacturers, Importers and Distributors are responsible for evaluating the hazards of their products, developing labels and safety data sheets. This information is used by companies that purchase these products.

Employer Responsibilities Manufacturer, Importer, Distributor Employer Employees Contractors Provide training and information to employees and contractors. Maintain labels, chemical inventory and safety data sheets Develop policies Maintain a written communication program. [SAY] Employers have additional obligations to: Train employees about the chemical hazards Maintain labels and place labels on transfer containers Maintain chemical inventories Maintain safety data sheets

Employee Responsibilities Employees Participate in training Know how to obtain chemical hazard information Review and follow label and safety data sheet instructions before product handling and use Follow other policies and procedures Never work with a chemical you are unfamiliar with Contractors Note to the Instructor: The point of this slide is to clearly identify employee (your audience) responsibilities. Important to stress that they should always read labels and SDS! [SAY] Finally we have all of us as employees or as contractors at a customer site. Regardless of where you are, you are basically both because for us you are the employee and for the customer you are the contractor. With this in mind, we have to remember to always participate in all required training from Ecolab and from your customers and follow all policies and procedures for safe chemical handling.. [ASK] Anyone here knows where would you obtain chemical hazard information at the customer site? [The answer should be anywhere from asking your contact person or safety department at the customer site or SDS station can also be answered] Labeling is very important to obtain hazard information before you handle a chemical container. [ASK] What would you do if a customer person asks you to handle a chemical that has no labeling? [pick someone from class to participate] [EMPHASIZE] We should NOT agree to handle until is properly labeled and they are trained to do so.

Chemical Hazard Concepts [SAY] The next few slides introduce exposure control best practices. We have to understand and practice very seriously to protect our body correctly against harm every single time we work with hazardous materials.

Match the term with its explanation below. Chemical Affects Match the term with its explanation below. Chronic Effects Acute Effects Dosage Amount of hazardous material you are exposed to Short-term effects that usually disappear when you are no longer exposed [Get participation from class on this slide to get the answers. Discuss the definitions without saying what it is and let 3 participants tell you one by one which matches with the definition] [SAY] The kind of exposure you have to a chemical often determines how the chemical might affect your health. The dosage refers to the amount of the chemical you are exposed to. With some materials, it takes a very large amount to do any serious harm, but with others, only a tiny amount can be very dangerous. Dosage also depends on duration of exposure, concentration of material, and exposure pathway. Acute effects are short-term effects on the body that usually disappear if you are no longer exposed. Examples include skin irritation from touching a chemical, or irritation of your nose and throat from inhaling fumes. Chronic effects are long-term effects that develop over a long period of exposure—even exposure to small amounts. Examples include health related illnesses. Long-term effects that develop over a period of exposure

Chemical Exposure Routes Direct contact Skin absorption Eye absorption Inhalation Ingestion Injection (punctures) [SAY] Materials can enter your body in several ways. Three most common ways are: Direct contact Skin absorption or contact with the eyes; this is especially true of liquid materials; and Inhaling hazardous fumes, vapors, mists, or dust. These can be taken into the lungs and travel from there into the bloodstream and to other organs of the body. Less common is ingestion and injection. Ingestion commonly occurs from poor hygiene – not washing hands, etc. after handling chemicals. Injection can occur when the skin is punctured or through open wounds. Primarily occurs in the medical industry (needle sticks)

Health Hazards – Key Terms Description Corrosives Substances that can cause irreversible damage to the eye, skin or respiratory system. Irritant Can cause a reversible inflammatory effect on eyes, skin and respiratory system. Sensitizers Induces an allergic reaction / response to the respiratory system or skin – often upon repeat contact. Toxic Capable of causing serious injury or death dependent upon exposure dose. Carcinogen Can induce cancer or increase its incidence. Mutagen Can cause change to genetic material in cells. Reproductive Toxin Can cause adverse effects to sexual function, fertility or development of offspring. Pesticides Substances intended for preventing, destroying, repelling, or mitigating any pest. Biocides are a subset. [Depending on your audience, you can refer to specific products. ] [SAY] These are common terms related to “health” hazard classification. Corrosives are those substances that in contact cause irreversible damage to us. Irritants do cause damage as well but is more of an inflammatory reversible effect. Now sensitizers are those that when exposed to, over time a smaller amount can trigger an allergic reaction such as respiratory or also skin rash. Example: If you become sensitized to a biocide then household products like soaps and shampoos can trigger an allergic rash on your body. Toxic substances are those that cause injury or even death depending to the concentration because basically the body cannot handle the substance to eliminate it. Example includes lead, formaldehyde, etc. Carcinogens are those substances that cause cancer like asbestos Mutagens are those substances that when exposed cause mutations in DNA Reproductive toxins can cause adverse effects to sexual function, fertility or developmental offspring Pesticides are intended to prevent, destroy, repel or mitigate any pest. Our biocides are a subset of pesticides The most common “hazardous” Ecolab products are corrosive and irritants. Note to the instructor: Take your time with explaining this slide. These are important concepts.

Physical Hazards – Key Terms Description Flammable Liquid with a flash point < 140oF. Flash point is the temperature at which a liquid gives off enough vapor to ignite in the presence of an ignition source. Combustible Liquid with a flashpoint >140oF and <200oF. Oxidizer Material that can yield oxygen, thereby contributing to the combustion of other materials. Reactive Material (liquid, solid or gas) that is thermally unstable and can undergo violent reaction by itself or in combination with other materials (e.g. water reactive). Organic Peroxide Special designation of reactive chemicals which may undergo exothermic decomposition. May burn rapidly, be sensitive to shock or friction, or react with other substances. Others Flammable solids / gases, explosives, gases under pressure, self-heating chemicals [SAY] Here we have the most Common physical hazard terms. When we talk about flammables, it is important to note that in the US, OSHA now considers a flammable to have a flash point <140oF. Previously, it was 100oF. We are basically talking about the flashpoint - temperature in which the liquid can release vapors that can ignite if they encounter an ignition source. [ASK] What could be an ignition source? [Get class participation] Examples include spark, truck engine, welding, etc. Combustibles are those with flashpoint between 140ºF and 200ºF Oxidizers are those chemicals that when exposed to the air will release oxygen. Oxygen is not good because it can contribute to having an explosion. Remember that to have a fire/explosion you need 3 basic elements to react: Heat, Oxygen and Fuel (something that can burn) Reactive substances are those that you really want to spend quality time studying the SDS because if not handled safely as indicated they can get very unstable and undergo violent reactions by themselves or with other materials. Pay very close attention if you work with reactive chemicals. Organic Peroxides undergo exothermic decomposition and may burn rapidly. These substances are very sensitive to shock, friction or react with other substances. Then we have other categories such as flammable solids/gases, explosives, gases under pressure and self-heating chemicals. Again they key here is to have a very good understanding what we are dealing with BEFORE we proceed.

Container Labeling [SAY] The next few slides introduce exposure control best practices. We have to understand and practice very seriously to protect our body correctly against harm every single time we work with hazardous materials.

National Fire Protection Association [SAY] NFPA = National Fire Protection Agency – most common in the US. The label will display a number from 0 to 4 for Health, Fire, and Reactivity. Basically, if you think about it its easy, the higher the number, the higher the hazard. These numbers are commonly found on safety data sheets. [ASK] When you see a high number on the health [point at the blue section], what should come to mind? [Get class participation.] [ANSWER] You should get an answer like “I need to protect my health more – so the use of PPE is more critical here [ASK] Now how about in the red area? [Get more class participation. You are looking for an answer like “ look for ignition sources and keep the material enclosed so it does not release flammable fumes, plus monitor temperature and other components that may cause fire like corrosives or fuel or oxidizers The label also has a section for special hazards – such as oxidizer, acid, corrosive.

Hazardous Materials Identification System [SAY] HMIS = Hazardous materials Identification System. The HMIS that is used for routine operations. What additional information we see the label asking here? (Ask the audience) Answer: PPE information. Some customers require you to use a legend to determine the PPE to be used to handle chemicals. Other customers simply will ask you to write it clearly on the HMIS label. Uses a similar 0 to 4 rating system.

Example [SAY] Ecolab In-House – this hazard ratings system is owned and copyrighted by Ecolab for exclusive use on Ecolab product labels. The ratings are general hazard ratings and are the same as the other rating systems. We started using this system in approximately 1997, so any product labels that have been updated or created since that time include this ratings system. The only label exceptions are EPA-registered sanitizers – EPA does not allow us to place our hazard system on those labels – and FDA drug products – hand cleaners/sanitizers that require Drug Fact panels. The same is true for Ecolab MSDS. We include the ratings in the upper right hand corner of each MSDS.

Pesticide / Biocide Label [SAY] Pesticide and biocide labels are specific labels approved by the EPA. They are generally more prescriptive that other common label systems.

Department of Transportation (DOT) [SAY] Containers shipped in the US will also contain Department of Transportation labels. If you think about it, these placards will even help you assess the risk in case you are in traffic and see a truck with a hazardous material placard that is in the middle of a spill. You may be able to drive away from the situation. [ASK] Would you agree that it is a good practice to stay away from vehicles with hazardous material placards?

Upcoming Changes Globally Harmonized System for Classification and Labeling of Chemicals - GHS United Nations (UN) international mandate to standardize classification, labeling, safety data sheets and hazard symbols Being implemented around the world Varying schedules US – 2012 to 2015 Canada - TBD

New GHS Label Elements New Signal Words Standardized Hazard Statements “Warning” – less severe hazard “Danger” – more severe hazard Standardized Hazard Statements Examples – “Highly flammable liquid and vapor”, “Causes skin irritation” Standardized Precautionary Statements Examples – “Wear protective gloves”, “Do not breathe vapors” Pictograms

Pictograms – Fire Hazards Flammable Pyrophoric Self-Heating Emits Flammable Gas Self-Reactive Organic Peroxide Oxidizer Flame Flame Over Circle [SAY] Pictograms are standardized to the hazard type. For example, the above pictograms are designed to represent flammable and oxidizing hazards. Again, the intent is so these symbols can be understood throughout the world.

Pictograms – Health Hazards Skin Corrosion / Burns Eye Damage Corrosive to Metal Irritant (skin and eye) Skin Sensitizer Acute Toxicity (harmful) Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (environmental) Corrosion Exclamation Mark [SAY] Pictograms representing various health hazards.

Pictograms – Health Hazards Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity Acute Toxicity (Fatal or Toxic) Health Hazard Skull & Crossbones [SAY] These are the pictograms representing health hazards. Any product deemed a health hazard will contain one of these on the label.

Pictograms – Physical Hazards Explosives Self-Reactive Organic Peroxide Gases Under Pressure Exploding Bomb Gas Cylinder [SAY] These are the pictograms representing physical hazards.

Pictograms – Environmental Hazard Aquatic Toxicity Environment [SAY] This is the pictogram for environmental hazards. Note that OSHA does not enforce or require the use of this but it is available as an option for chemical manufacturers to include. The Environmental Pictogram is non-mandatory for products sold in the United States.

Required Label Elements [SAY] This is a generic product label containing GHS elements. Note the regulation specifies the elements that must be present on the label but manufacturers are still free to design the layout as they see fit. The next few slides will explain each required element in more detail.

The common name of the product, along with any other identifiers (e. g The common name of the product, along with any other identifiers (e.g. product number) must be prominently displayed. [SAY] In this section, you will find the common name of the product, along with any other identifier such as product number is required to be displayed.

The name, address and telephone number of the manufacturer, importer or other responsible party must be listed. [SAY] Here you will find the name, address, and telephone number of the manufacturer, importer or other responsible party must be listed.

The GHS pictograms for the product are also displayed The GHS pictograms for the product are also displayed. In this example, “Health” and “Fire” hazards. [SAY] The pictograms relevant for the product must also be displayed. In this case, pictograms related to Health and Fire hazards.

The appropriate Signal Word is listed The appropriate Signal Word is listed. Remember, “Danger” indicates a higher degree of hazard than “Warning”. [SAY] The appropriate Signal Word must be included. In this case, its “Danger” which represents a higher degree of hazard than “Warning”. Note that previously, “Caution” was often used as a Signal Word. GHS phased this out.

The appropriate Hazard Statements are given The appropriate Hazard Statements are given. In this case, representing the degree of flammability and the target organ potentially impacted (toxicity). [SAY] Appropriate hazard statements must be included. These represent the relative degree of the hazard. Highly flammable and damage to specific target organs in this example.

Precautionary Statements related to the Health and Fire hazards are displayed. Note there are statements related to Prevention, Response, Storage and Disposal. These statements are largely standardized by regulation, with the manufacturer adding additional information. [SAY] Precautionary statements are also listed. There are 4 types of hazard statements related to: Exposure Prevention – Basically how to protect yourself Response – In case of emergency information Storage – How to store the product safely Disposal – How to dispose in compliance with regulations [Point out at least one for each of these types.]

Additional, non-mandatory information can be added by the product manufacturer. May not conflict with or contradict other hazard information [SAY] Manufacturers are allowed to add additional, pertinent information and instructions to the product labels. However, it must not contradict or conflict with any of the required information.

Going Forward In-House, HMIS, and NFPA labels will become less prominent as manufacturers move to the GHS labeling system through 2015. DOT and pesticide labels will remain until additional regulations are promulgated.

Safety Data Sheets [SAY] The next few slides introduce exposure control best practices. We have to understand and practice very seriously to protect our body correctly against harm every single time we work with hazardous materials.

General Requirements Must be available for each hazardous chemical used Must be in English but can also be made available in other languages GHS requires a 16 section standardized format. Previously, manufacturers could choose the format. GHS-compliant SDS must be in place no later than 2015.

SDS Required Elements Identification Hazard Identification Composition Information First-Aid Measures Fire-Fighting Measures Accidental release measures Handling and Storage Exposure Controls / Personal Protection Physical and Chemical Properties Stability and Reactivity Toxicological Information Ecological Information Disposal Considerations Transport Information Regulatory Information Other Information Note to the Instructor: Best practice is to have a sample available so students can follow along. [SAY] These are the required elements of a GHS compliant SDS. You should touch briefly on each section. [These next few slides will focus on several specific sections but will not detail each one.]

Section 2 describes the product hazard and includes many of the same elements as the label – Signal Words, Pictograms, Hazard Statements, and Precautionary Statements. [SAY] Section 2 describes the product hazards and includes many of the same elements present on the label.

Our SDS describes hazards both “As Sold” and “At Use Dilution” Our SDS describes hazards both “As Sold” and “At Use Dilution”. “Use Dilution” hazard are more representative of the product as used by the customer. Most chemical manufacturers do not provide this. [SAY] Ecolab SDS have an added feature that describes the hazards of the product both as shipped and when used at use-dilution. Most manufacturers do not include this.

Section 4 includes important instructions should you be exposed to the product. [SAY] Section 4 includes important instructions if exposure were to occur. Keep in mind to check at the customer site that the emergency medical services knows what to do to treat medical emergencies related to the chemicals you work with. [ASK] Why is this so important? [Let the participants think. You should get an answer such as “because we can reduce the time to address the emergency if they know how to proceed”]

Section 7 includes details for proper storage and handling practices. Section 8 outlines needed exposure control measures, including necessary personal protective equipment. [SAY] Section 7 can be referenced for guidance on storage and handling. If you store the product with incompatibles and there is a spill where they react, it will not be a good situation and people can get hurt, plus impact to the environment and community. Section 8 includes exposure control information, including necessary personal protective equipment. Here is where you find information on how to isolate your body against accidental exposures. Never hesitate to upgrade any PPE that is written here if based on your risk assessment you see its necessary.

Obtaining SDS Ecolab / PureForce product SDS available through www.ecolab.com Customers must have a system for making SDS available to all product users at their facilities

Product Disposal Guidelines You are responsible for product disposal Products may be classified as hazardous waste due to characteristics such as corrositivity or flammability Only a licensed hazardous waste disposal company Never pour product into a drain unless the SDS indicates it is safe to do so

Questions? [SAY] The next few slides introduce exposure control best practices. We have to understand and practice very seriously to protect our body correctly against harm every single time we work with hazardous materials.