2013 Training Requirements for the Revised OSHA Hazard Communication Standard This presentation (“Employers Hazcom Training Requirements”) summarizes the 2013 training requirements for OSHA’s revised Hazard Communication Standard. It is intended to provide employers and trainers with background on the new requirements. A supplemental presentation (“Workers Hazcom Training”) is available for use as a suggested training program for workers. Since workers are the target audience, these presentations emphasize hazard identification, avoidance, and control – not standards. No attempt has been made to treat the topic exhaustively. It is essential that trainers tailor their presentations to the needs and understanding of their audience. This presentation is not a substitute for any of the provisions of the Occupational Safety and Health Act of 1970 or for any standards issued by the U.S. Department of Labor. Mention of trade names, commercial products, or organizations does not imply endorsement by the U.S. Department of Labor.

Introduction OSHA revised its Hazard Communication Standard to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Two changes require the use of new labeling elements and a standardized format for Safety Data Sheets (SDS), formerly known as Material Safety Data Sheets (MSDS). OSHA is phasing in the specific requirements over several years, December 1, 2013 through June 1, 2016. This is one of the most frequently cited OSHA standards. This program is intended for workplaces that do not manufacture, import, or distribute hazardous chemicals. Notes have been provided that highlight some of the requirements for these employers. For complete requirements, consult 29 CFR 1910.1200.

Introduction, cont. The first compliance date is December 1, 2013. By that date, employees must be trained on the new label elements and the Safety Data Sheet (SDS) format. This training is needed early in the transition process since employees will begin to see the new labels and SDSs on the chemicals in their workplace. To ensure employees have the information they need to better protect themselves from chemical hazards in the workplace during the transition period, it is critical that employees understand the new label and SDS formats.

Purpose of OSHA’s Hazard Communication Standard To ensure that employers and employees know about chemical hazards and how to protect themselves so that the incidence of illnesses and injuries due to hazardous chemicals is reduced. Hazard Communication Program Container Labeling Safety Data Sheet 29 CFR 1910.1200 The Hazard Communication (HazCom) standard establishes uniform requirements to make sure that the hazards of all chemicals imported into, produced, or used in U.S. workplaces are evaluated, and that this hazard information is transmitted to affected employers and exposed employees. The HazCom standard is different from other OSHA health rules because it covers all hazardous chemicals. The rule also incorporates a “downstream flow of information,” which means that producers of chemicals have the primary responsibility for generating and disseminating information, whereas users of chemicals must obtain the information and transmit it to their employees. Program SDS Label

Employer Responsibilities Identify and list hazardous chemicals Obtain Safety Data Sheets (SDSs) Label hazardous chemicals Implement a written Hazard Communication Program, including labels, SDSs, and employee training Train employees (f) "Labels and other forms of warning." (g) “Safety Data Sheets." (h) "Employee information and training." HazCom Program

The Written Program Hazardous Chemical List SDS Labels Non-Routine Procedures Training

How must chemicals be labeled? Each container of hazardous chemicals entering the workplace must be labeled or marked with: Product identifier Signal word Hazard statement(s) Pictogram(s) Precautionary statement(s) Name, address and telephone number of the manufacturer, importer, or other responsible party 1910.1200(f) Chemical manufacturers and importers must convey the hazard information to downstream employers by means of labels on containers and Material Safety Data Sheets (MSDSs). Language used on the warning label does not have to be identical to that on the MSDS. Chemical manufacturers, importers, and distributors must be sure that containers of hazardous chemicals leaving the workplace are labeled, tagged, or marked with: - the identity of the chemical, - appropriate hazard warnings, and - the name and address of the chemical manufacturer, importer, or other responsible party Consumer products having labels meeting requirements of the Consumer Product Safety Act do not have to have additional labeling under the HazCom Standard. Various other chemical products (for example, pesticides, foods, drugs, cosmetics, beverage alcohols) that are subject to labeling laws administered by other Federal agencies are also exempt from the labeling requirements of the HazCom Standard.

Label Elements Product identifier Signal word Pictogram(s) Chemical name, code number, or batch number Signal word “Danger” or “Warning” Pictogram(s) Black hazard symbol with red frame.

Label Elements, cont. Hazard statement(s) Precautionary statement(s) Describe the nature of the hazard(s) of the chemical, including where appropriate, the degree of hazard. Precautionary statement(s) A phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure. Name, address and telephone number of the chemical manufacturer, distributor, or importer

Use of Labels in the Workplace Information on the Labels can be used to ensure proper storage of hazardous chemicals Information on Labels can be used to quickly locate information on first-aid when needed by employees or emergency personnel

How Information on Labels Work Together When a chemical has multiple hazards, all applicable Pictograms are used to identify the various hazards. But, when there are similar precautionary statements, only the one providing the most protective information will be the one included on the label.

Pictograms Health Hazard Flame Exclamation Mark Carcinogen Flammables Irritant (skin & eye) Reproductive Toxicity Self-Reactives Skin Sensitizer Respiratory Sensitizer Emits Flammable Gas Acute Toxicity Target Organ Toxicity Pyrophorics Narcotic Effects Aspiration Toxicity Self-Heating Respiratory Tract Irritant Mutagenicity Organic Peroxides It is important to note that the OSHA pictograms do not replace the diamond-shaped labels required by the U.S. Department of Transportation (DOT) requires for the transport of chemicals, including chemical drums, chemical totes, tanks or other containers. Those labels must be on the external part of a shipped container and must meet the DOT requirements set forth in 49 CFR 172, Subpart E.

Pictograms Gas Cylinder Corrosion Exploding Bomb Gases Under Pressure Skin Corrosion/Burns Explosives Eye Damage Self-Reactives Corrosive to Metals Organic Peroxides

Pictograms Flame Over Circle Skull and Crossbones Oxidizers Acute Toxicity (fatal or toxic)

Safety Data Sheets (SDS) Prepared by the chemical manufacturer or importer and describe: Physical hazards, such as fire and explosion Health hazards, such as signs of exposure Routes of exposure Precautions for safe handling and use Emergency and first-aid procedures Control measures Must be readily accessible to employees in their work area 1910.1200(g) Chemical manufacturers and importers must develop an MSDS for each hazardous chemical they produce or import, and must provide the MSDS at the time of the initial shipment to a downstream distributor or user. Distributors also must ensure that downstream employers are similarly provided an MSDS. The MSDSs must be updated by the chemical manufacturer or importer within three months of learning of "new or significant information" regarding the chemical's hazard potential. OSHA does not require that MSDSs be provided to purchasers of household consumer products (such as "windex" and "white‑out“) when the products are used in the workplace in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience. Employees who are required to work with hazardous chemicals in a greater duration and frequency of exposure than a normal consumer have a right to know about the properties of those hazardous chemicals.

Safety Data Sheets (SDS) Format: 16 Sections Identification Hazard(s) identification Composition/information on ingredients First-aid measures Fire-fighting measures Accidental release measures Handling and storage Exposure control/personal protection

Safety Data Sheets (SDS) Format: 16 Sections (cont.) Physical and chemical properties Stability and reactivity Toxicological information Ecological information Disposal information Transport information Regulatory information Other information

Safety Data Sheet (SDS) sample SDS are useful for: Learning potential hazards Determining safe handling procedures Emergency response Example: send a copy along with an employee going to the Doctor after an incident.) Employers must ensure that SDSs are readily accessible to employees for all hazardous chemicals in their workplace. This may be done in many ways. For example, employers may keep the SDSs in a binder or on computers as long as the employees have immediate access to the information without leaving their work area when needed and a back-up is available for rapid access to the SDS in the case of a power outage or other emergency.

Training Training is required for employees who are exposed to hazardous chemicals in their work area: At the time of initial assignment Whenever a new hazard is introduced into their work area 1910.1200(h) Training is not satisfied solely by giving the employee the data sheets to read. An employer's training program is to be a forum for explaining to employees not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program. This can be accomplished in many ways (audiovisuals, classroom instruction, interactive video), and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them. Training must be carried out in a language that is comprehensible to the employees. Training need not be conducted on each specific chemical found in the workplace, but may be conducted by categories of hazard (e.g., carcinogens, sensitizers, acutely toxic agents, irritants, flammables) that are or may be encountered by an employee during the course of his duties. Employees who have been previously trained by another employer, union, or other entity, do not have to be retrained if the previous training is sufficient to meet the standard’s training requirements for the current work being performed. However, employees must have information about where to find MSDSs in the workplace, who in the company is responsible for the HazCom program, and where to get copies.

What training is needed to protect workers? Explanation of the Hazard Communication program, including information on labels, SDSs, and how to obtain and use available hazard information Hazards of chemicals Protective measures such as engineering controls, work practices, and the use of PPE How to detect the presence or release of a hazardous chemical (using monitoring devices, observation, or smell)

What information must be provided to workers? Employees must be informed of: The Hazard Communication standard and its requirements Operations in their work areas where hazardous chemicals are present Location and availability of the written hazard communication program, list of hazardous chemicals, and the required SDSs

Summary OSHA’s Hazard Communication Standard is based on a simple concept - that employees have both a need and a “right-to-know” about the hazards and identities of the chemicals they are exposed to when at work. Employees also need to know what protective measures are available to prevent adverse effects. See www.osha.gov for more information on hazard communication, including the following publications: Hazard Communication Guidelines for Compliance – OSHA 3111 (This is the same information that is contained in Appendix E to 1910.1200 and is also available in Spanish.) Chemical Hazard Communication – OSHA 3084 (This is also available in Spanish.)

2013 Training Requirements for the Revised OSHA Hazard Communication Standard