Update on the Implementation of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) at the Hanford Site Raja Atallah*, PhD, Mark Hermanson, and Pete Wells Mission Support Alliance, Richland, WA June 2015

GHS Introductory Video

Introduction OSHA Adopts GHS in March 2012 OSHA Established an Implementation Timeline DOE Directed Mission Support Alliance (MSA) in June 2012 to Take the Lead for Hanford Implementation Hanford Inter-Contractor Work Group Established, June 2012

Effective Completion DateRequirement(s)Who December 1, 2013Train employees on the new label elements and safety data sheet (SDS) format. Employers June 1, 2015 December 1, 2015 Compliance with all modified provisions of this final rule, except: The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label Chemical manufacturers, importers, distributors and employers June 1, 2016Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers Transition Period to the effective completion dates noted above May comply with either 29 CFR (the final standard), or the current standard, or both Chemical manufacturers, importers, distributors, and employers GHS Implementation Timeline

Implementation Process Training Hazard Container Labeling: Primary and Secondary Document Revisions: Chemical Management and HAZCOM Procedures Modified Data Bases Transition and Communication

Training Implementation at Hanford Worked with EFCOG on Developing Training Updated Hanford General Education Training (HGET), November 2012 (Video) Updated HAZCOM Section of the Hazardous Waste Operations and Emergency Response (HAZWOPER), Training, November 2012 Developed Advanced GHS HAZCOM Training Updated the HAZCOM section for the Workers Basic HAZCOM Training

Hanford General Employee Training (HGET): Hazardous Waste Operations and Emergency Response (HAZWOPER): Basic HAZCOM Training Site-Location Specific Training Workers Training

Advanced GHS Training Provide in-depth training to professionals who will be advising workers or assisting with work planning Provide in-depth training to professionals who will be preparing and conducting GHS training to workers. Professionals attend the training Training duration four hours

Advanced GHS Training Course Outline Introduction to GHS Overview of the Revised HAZCOM Standard Summarize Criteria for Health, Physical and Environmental Hazard Classifications Discuss Elements of the GHS label and Safety Data Sheet Present Hanford Implementation of GHS: (Training, Labeling, Databases, Webpage, Document Revisions, Chemical Procurement Forms, Job Hazard Analysis) Discuss Changes Made or Anticipated by Other Organizations or Agencies

The Nature of Chemical Hazards OSHA Defined & Listed Hazard Classes Pyrophoric Gases Combustible Dusts Simple Asphyxiant Hazards Not Otherwise Classified OSHA Defined & Listed Hazard Classes Pyrophoric Gases Combustible Dusts Simple Asphyxiant Hazards Not Otherwise Classified

Globally Harmonized System (GHS)

GHS Poster

GHS Poster Example elements of the Standard Health Hazards

Physical Hazards GHS Poster Example elements of the Standard

OSHA Defined / Listed Hazards (Label Elements)

Hazard Class / Category Determination Criteria OSHA - 29 CFR Appendix A Example Health Hazard: Acute Toxic (Oral, Dermal, Inhalation)

Hazard Class / Category Determination Criteria United Nations GHS Standard (The Purple Book) Example Health Hazard: Acute Toxic (Oral, Dermal, Inhalation)

Summary of Changes to HAZCOM Health Hazards

Summary of Changes to HAZCOM Health Hazards

Summary of Changes to HAZCOM Health Hazards

The GHS standard defines the label elements that must be placed on the primary (manufacturer’s) container. However, the GHS-HCS only established a general guideline for labeling the secondary (site repackaged) container. This guideline requires employers to use words, pictures, symbols, and other information to inform their employees on the physical and health hazards of the hazardous chemical. Primary and Secondary GHS Labeling

GHS Manufacturer Label Elements Review Product Name/Identifier Pictogram(s) Signal Word Hazard Statements Precautionary Statements Supplementary Information Manufacturer Name and Emergency Contact

Workplace Labeling Secondary Container Labels Product Name/Identifier Pictogram Signal Word Hazard Statements Manufacturer Name Added Hanford GHS-SDS Number Removed Precautionary Statements Removed Manufacturer’s Emergency Contacts

OSHA Requirements are Imprecise Basic Content Hanford Workplace Labeling Product & Manufacturer Hanford Unique SDS Number Color Coding Signal Words and Pictograms Hazard Statements No Precautionary Statements No NFPA 704 Hazard Ratings The Value of Standardization Possible Harsh Environments EFCOG Best Practice Radio Frequency Identification Workplace Labeling Secondary Container Labels

NFPA-704 Hanford Hazard Container (HHC) Label Flammability Health Instability (Formerly Reactivity) Specific Hazard: Oxidizer, (OX) Water Reactive (W) NFPA-704 Degrees of Hazard 0-4

NFPA-704 (HHC) / GHS (HHC) Labels

Ammonium Sulfamate JT Baker Harmful if Swallowed Making Secondary Container Labels None

GHS (HHC) Label Variations

SDS and Secondary Label

The Best Practice on GHS compliant Hazard Label was awarded the 2015 EFCOG teamwork award for exceptional performance by a group of individuals who were instrumental in addressing a key EFCOG issue. Mark Hermanson - MSA Jeff Hieb - ATL Mikhail Alnajjar - PNNL Bruce Dickey - MSA Raja Atallah - MSA EFCOG Teamwork Award

Hanford Implementation Plan - Labels

SDS-MSDS and CITS Databases Chemical Inventory Tracking System Used by all Hanford Contractors for Inventory Tracking/Reporting Product by Manufacturer Identifies Constituents NFPA Hazard Ratings GHS Hazard Class, Category, and Statements Safety Data Sheet – Material Safety Data Sheet Used by all Hanford Contractors for Basic Haz Com All Current and Past SDS-MSDS Documents Assigns a Hanford Unique SDS-MSDS Document Number Distinguishes Between SDS and MSDS Formats Product Name, Synonyms, Manufacturer, and Catalogue ID SDS-MSDS Date DATADATA

SDS – MSDS Database

Labeling MSDS and SDS Documents

CITS Database GHS Hazard Information Report

Required Changes to Procedures, Forms, Databases

Examples of Procedures, Forms, and Databases

Hanford’s GHS Web Page

Implementation Plan Planned Action Implementation Process (Requirement) Implementation Date and Status Establishing Hanford GHS Working Group Hanford contractors meet to coordinate actions and share ideas on the how to implement the revised standard. Members are made of training managers, HAZCOM subject matter experts, chemical management program personnel, industrial hygienists, CITS and SDS administrator. (Best Practice) DOE Letter of Direction to MSA, G. H. Branch/RL J. F. to Armijo/MSA Correspondence # A dated 11/05/2012.DOE Letter of Direction to MSA Group meetings started in April 2012 and keep meeting per need at HAMMER Facility. See the GHS Web Page for meeting schedule, dates and minutes.GHS Web Page HAZCOM section part of Hanford General Employee Training (HGET) Training material was revised by training managers and HAZCOM subject matter experts. The revised material included a GHS video and new slide on the new GHS elements. This training meets the OSHA requirements of providing workers initial GHS- HAZCOM training on the GHS elements by December (29CFR (j)(1) Effective Dates) HGET is required annually for all Hanford employees. The new GHS HAZCOM part of HGET training was began November 2012 and completed by all Hanford employees by the OSHA deadline of December Training for new workers requires watching the five minutes GHS HAMMER video. Video is optional when retaking the training. GHS Web Page Establish a web page to Announce available training and other activities; provide links to tools, resources, and related information; identify points of contact; and highlight communications. GHS Web PageGHS Web Page established May 2012 and is updated regularly.

Transition Communication

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