Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS & HAZCOM 2012 Compliance Deadlines: Are You Ready? 1

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Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Goals for this Presentation Avoid This…. Brief Review of OSHA’s HCS Discuss OSHA’s Alignment with the GHS Understand reasons for adoption Learn how to comply 3

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Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. What is HCS? Hazard Communication Standard An OSHA Regulation – protect workers from hazardous chemicals Adopted in 1983 Covers 43+ Million U.S. Workers 5 Million Workplaces Over 880,000 Chemicals 7

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Purpose of HCS “…to ensure hazards of all chemicals produced or imported are evaluated and details regarding their hazards are transmitted to employers and employees” “Ensure requirements are consistent nationwide” 8

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Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Chemicals Covered – HazCom 1994 Physical Hazards  Combustible Liquids  Compressed Gases  Explosives  Flammables  Organic Peroxides  Oxidizers  Pyrophorics  Unstable (Reactive) Materials  Water-Reactives 11

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Chemicals Covered – HazCom 1994 Health Hazards Chemicals that may produce acute or chronic health effects in exposed employees. Nephrotoxins Neurotoxins Agents which act on the hematopoietic system Agents which damage the lungs, skin, eyes or mucous membranes Carcinogens Toxic agents Reproductive toxins Irritants Corrosives Sensitizers Hepatotoxins 12

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Who has Responsibilities Chemical Manufacturers  Evaluate and now also classify hazards of chemicals  Provide labels & MSDSs to employers to which they ship chemicals Importers & Distributors  Provide labels & MSDSs to employers to which they ship chemicals Employers Who “Use” Chemicals Are responsible for the following as part of a compliant HazCom program: 1. Written Hazard Communication Plan / Program 2. Written Chemical Inventory 3. Ensuring proper use of Labels and Warnings 4. Maintaining MSDSs and providing Right-to-Know access to employees 5. Providing Employee Training 13

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. The Problem Regulations vary widely internationally  E.g., U.S. has HazCom Standard, Canada has WHMIS, Europe has CLP Different agencies within the same country may have jurisdiction over hazardous chemical use and safety  E.g., in the U.S.: EPA, DOT, OSHA, Consumer Product Safety Commission Multiple labels & MSDSs required for same product to satisfy different country & agency requirements  Resulting in confusion for end-users  Creating trade issues/hassles multinational companies  Costly & time consuming to manage When it comes to Hazard Communication… 14

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Enter GHS GHS = Globally Harmonized System of Classification and Labelling of Chemicals  1 st edition approved in 2002 and published by UN in 2003 Result of international mandate (Chapter 19 of Agenda 21) from 1992 Rio Earth Summit (i.e.,UNCED)  Deemed to be single most important driving force behind the creation of GHS  Aimed to be completed GHS by 2000  A coordinating group chaired by OSHA was established to manage the work Common & coherent global approach  To Classifying and Defining & Communicating Hazards  Provides Consistency/ Harmonization to Labels and Safety Data Sheets 15

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS At-A-Glance GHS is Not…  A Regulation, Standard or Mandate GHS is…  A Best Practices Approach. It contains criteria, provisions, and explanatory text for harmonizing hazard communication  Adaptable by Country (and Agency)  Referred to as the “Building Block Approach”  Select parts of system that apply to existing regulations  Implementation consistent with requirements in place, or can use to create new requirements 16

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Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. OSHA Alignment with GHS Revise HCS to Align with GHS  Maintain HCS framework  Enhance protection  Based on GHS Rev 3 (2009) Major Changes  Chemical Classification  Safety Data Sheets (SDSs)  Labels Compliance Enforcement – Phased In  Employees Trained on How to Read SDS/Label by Dec. 1, 2013  Manufacturers and Distributors Complete Reclassification and Produce Updated SDSs and Labels by June 1, 2015  Distributors may ship inventory with old SDS/Labels until Dec. 1, 2015  Full Employer Compliance Expected by June 1, 2016  Transitional Period can comply with old or new HCS/HazCom

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS Alignment Timeline 1 Dec. 1, 2013 ─ EMPLOYERS Train on new label elements and SDS format 2 June 1, 2015 ─ MANUFACTURERS, DISTRIBUTORS & IMPORTERS Reclassify chemicals, and update all SDSs and labels to GHS format 3 Dec. 1, 2015 ─ DISTRIBUTORS Begin sending only GHS formatted SDSs and GHS labeled products 4 June 1, 2016 ─ EMPLOYERS Update alternative workplace labeling and HazCom Program as needed, and provide additional employee training for newly identified physical or health hazards ANYTIME during Transition EMPLOYERS, MANUFACTURERS, DISTRIBUTORS and EMPLOYERS Comply with either HazCom 1994, or HazCom 2012, or both

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. December 1 st Train Employees on: New label elements New safety data sheet format 1 st Deadline - Employee Training Why the Rush?

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Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Why Train on GHS? How would your employees do answering those same questions?

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Training on label elements:  How employees might use labels in the workplace  Understanding of how elements work together on a label  Bottom Line: Understand pictograms, signal words, hazard statements, precautionary statements, etc… Training on SDS format:  16 Sections (type of info found in each section)  How the information on label is related to SDS The Dec. 1, 2013 training deadline is not meant to address the specific hazards of chemicals in the workplace or the related protective measures Minimum Required Training Topics

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Principle’s of OSHA’s Alignment HCS requirements will not be reduced Modifications made to support GHS Not a total rewrite of the regulation Bulk of tech requirements in Appendices  Versus regulatory text  Largely apply to chemical producers vs. users OSHA estimates net savings for employers to be over $500 million/year 38

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. HCS / HazCom 2012 Appendicies Appendix A: Health Hazard Criteria Appendix B: Physical Hazard Criteria Appendix C: Allocation of Label Elements Appendix D: Safety Data Sheets Appendix E:Definition of "Trade Secret” Appendix F: Guidance for Hazard Classification Regarding Carcinogenicity 39

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Two Most Prevalent Changes Hazard Classification Criteria  Health & Environmental Hazards  Physical Hazards  Mixtures Hazard ‘Communication’  Labels  Safety Data Sheets  Training OSHA is referring to revised standard as “HazCom 2012” 40

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Two Most Prevalent Changes “"Classification" means to identify the relevant data regarding the hazards of a chemical; review those data to ascertain the hazards associated with the chemical; and decide whether the chemical will be classified as hazardous according to the definition of hazardous chemical in this section.” OSHA added the definition of Classification to the revised standard: 41

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Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS Hazard Classifications Health & Environmental  Acute Toxicity  Aspiration Toxicity  Skin Corrosion/Irritation  Serious Eye Damage/Eye Irritation  Respiratory or Skin Sensitization  Germ Cell Mutagenicity  Carcinogenicity  Reproductive Toxicity  Target Organ Systemic Toxicity – Single and Repeated Dose  Hazardous to the Aquatic Environment/Aquatic Toxicity  Hazardous to the Ozone Layer Physical  Explosives  Flammable – Gases, Aerosols Liquids, Solids  Oxidizers– liquids, solids, gases  Self-Reactive Substances  Self-Heating Substances  Pyrophoric – liquids, solids  Organic Peroxides  Corrosive to Metals  Gases Under Pressure  Water-Activated Flammable Gases New with GHS is the concept of severity: Most of these hazard classes are also subdivided into “hazard categories” to reflect the degree of severity of the effect New with GHS is the concept of severity: Most of these hazard classes are also subdivided into “hazard categories” to reflect the degree of severity of the effect 43

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. HazCom 1994 vs HazCom 2012 HCS/HazCom 1994 Gases Under Pressure Carcinogenicity GHS Alignment/ HazCom 2012 Compressed Gases Refrigerated Gases Liquefied Gases Dissolved Gases Carcinogenicity  Category 1  1A = Known  1B = Probable  Category 2  Suspected Note the numbering scheme: Lower the #, the more severe the hazard 44

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS Hazard Classifications Health & Environmental  Acute Toxicity  Aspiration Toxicity  Skin Corrosion/Irritation  Serious Eye Damage/Eye Irritation  Respiratory or Skin Sensitization  Germ Cell Mutagenicity  Carcinogenicity  Reproductive Toxicity  Target Organ Systemic Toxicity – Single and Repeated Dose  Hazardous to the Aquatic Environment/Aquatic Toxicity  Hazardous to the Ozone Layer Physical  Explosives  Flammable – Gases, Aerosols Liquids, Solids  Oxidizers– liquids, solids, gases  Self-Reactive Substances  Self-Heating Substances  Pyrophoric – liquids, solids  Organic Peroxides  Corrosive to Metals  Gases Under Pressure  Water-Activated Flammable Gases 45

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Under New OSHA Definition… OSHA incorporated new elements into its revised definition of Hazardous Chemical  To include 3 classes of chemicals defined in its HCS that weren’t in GHS, Rev. 3 “Hazardous Chemical” means any chemical which is classified as a 1) Physical hazard; or 2) Health hazard; or 3) Simple asphyxiant; or 4) Combustible dust; or 5) Pyrophoric gas; or 6) Hazard Not Otherwise Classified (HNOC) 46

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Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Label Pictograms Explosives Self Reactive Organic Peroxide Flammable Self Reactive Pyrophoric Self-Heating Emits Flammable Gas Organic Peroxides Oxidizers Gases Under Pressure Acute Toxicity (Fatal or toxic) Skin Corrosion Corrosive to Metals Serious Damage to Eye Carcinogenicity Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity Aspiration Toxicity Skin & Eye Irritant Dermal Sensitizer Acute Toxicity (harmful) Transient Target Organ Effects Harmful to Ozone Layer (Not mandatory) Environmental Toxicity Health Hazard Gas Cylinder Exploding Bomb Flame Flame Over Circle Corrosion Environment Exclamation Mark Skull and Crossbones (Not mandatory) 53

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Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Standardization Hazard ClassEU CLPUS OSHA HCS4 th UN GHS Physical Hazards FLAMMABLE GASES1/21/2/A (unstable gas)/ B (unstable gas) AEROSOLSFlammable Aerosols 1/21/2/3 (unflammable aerosols) FLAMMABLE LIQUIDS1/2/31/2/3/4 (US Adopted Cat. 4) Health Hazards ACUTE TOXICITY EYE DAMAGE/IRRITATION1/2A1/2A/2B TOXIC TO REPRODUCTION 1A/1B/2/ Effects on or via Lactation (Note that the cut-off value is 0.1% in US, not 0.3% and 3% in EU) Environmental Hazards ACUTE TOXICITY TO THE AQUATIC ENVIRONMENT 1Not Required1/2/3 CHRONIC HAZARD TO THE AQUATIC ENVIRONMENT 1/2/3/4Not Required1/2/3/4 HAZARDOUS TO THE OZONE LAYER 1Not Required1 Other Hazards OTHER UNIQUE HAZARDSEU Supplementary Hazards: EUH029 Contact with water liberates toxic gas & EUH014 Reacts violently with water, etc. OSHA-Defined Hazards: Pyrophoric Gas, Simple Asphyxiant, Combustible Dust 61

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Labels * Standardized under GHS Product/Chemical Identifier Supplier Identifier Hazard Pictogram(s)* Signal Word Hazard Statement(s)* 62 Six Main Elements

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Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Workplace Labeling Employers May Continue to Use Current Workplace-Specific Labeling Systems  If they contain required information  If they are consistent with new classifications Labels on Containers  Must not be removed or defaced  Must be immediately replaced Workplace Labels  Must be prominently displayed  In English  Other languages permitted (additionally) 64

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Workplace Labeling Best practice - Whenever possible, replicate the shipping label  OSHA says your Workplace Labeling System + Employee Training should = at least the Same Level of Understanding as Shipped Label OSHA says you can:  Use GHS shipped label  Use current system, so long as it :  Accounts for GHS changes  Doesn’t present conflicting information (with GHS changes)  When combined with your training, provides at least the same level of understanding as GHS shipped label  Includes use of alternative labeling systems like NFPA or HMIS 65

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Safety Data Sheets Redefined as Safety Data Sheets (SDS)  GHS includes 16-part format  Essentially the ANSI Standard Several Sections are not Mandatory  Sections  Ecological information  Disposal considerations  Transport information  Regulatory information  Outside of OSHA’s jurisdiction New Appendix D  Details what is to be included in each section = 66

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. SDS – Headings 1.Identification 2.Hazard(s) Identification 3.Composition/Ingredient Information 4.First-Aid Measures 5.Fire-Fighting Measures 6.Accidental Release Measures 7.Handling and Storage 8.Exposure Control/ Personal Protection 9.Physical & Chemical Properties 10.Stability & Reactivity 11.Toxicological Information 12.Ecological Information 13.Disposal Considerations 14.Transport Information 15.Regulatory Information 16.Other Information 67

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Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. SDS – To Do Make sure staff is on the lookout for new, GHS formatted SDSs  Especially for chemicals you receive regularly Talk to your chemical suppliers and ask about their plans to transition to GHS  The sooner the switchover happens, the easier it will be on all of us Be in active preparation mode for GHS training  Have a plan and make sure employees are ready to read the GHS SDSs and labels 69

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Pretty much everyone who “uses” hazardous chemicals has some responsibility… some more than others Who’s Affected? Chemical Manufacturers have some work to do around re-classifying chemicals, and then re- authoring MSDSs, labels and warnings to make them GHS compliant Resellers, Distributors, Importers get new MSDSs and labels ASAP & distribute to customers Employers... 70

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Inventory your on-site chemicals Make sure you have a complete library of MSDSs Employers... Have an HCS plan! Maintain a checklist of key plan components Review it annually, at least Prepare yourself for the eventual MSDS churn If you’re still using paper, consider transitioning to electronic system Make sure your secondary labeling system is GHS compliant Start developing a training plan for your employees Stay current on OSHA  Federal  State & local Keep an eye on GHS  Key dates  Impact on your plan Request GHS compliant SDSs from chemical vendors Ensure staff is on the lookout for SDSs with new shipments Stay SARA compliant 71

Copyright © , MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Penalties for Noncompliance Are Very Real From 2009 – 2012 OSHA cited over 24,000 instances of HCS violations in workplaces across the United States #2 on OSHA’s top 10 list of most frequently cited compliance standards for 2012 Source: 72

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