1. 1 GHS/HazCom 2012 Deadlines: Are You Ready?

2. 2 Brad Harbaugh Editor of the EH&S Blog, MSDSonline

3. 3 Intro GHS and OSHA’s Adoption Deadlines and Responsibilities 2013 Training GHS Compliance Best Practices FAQs Goals for this Presentation

4. 4 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 What is HCS?

5. 5 Who has Responsibilities 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

6. 6 The Problem Regulations vary widely internationally Within a country, regulations vary widely among agencies with jurisdiction over hazardous chemicals Multiple labels & MSDSs often required for same product being shipped to different locations Workers see different labels and MSDSs for similar products from different manufacturers

7. 7 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) Common & coherent global approach To Classifying and Defining & Communicating Hazards Provides Consistency/ Harmonization to Labels and Safety Data Sheets Enter GHS

8. 8 GHS is Not… A Regulation, Standard or Mandate GHS is… Collection of best practices 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 GHS At-A-Glance

9. 9 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 OSHA Alignment with GHS

10. 10 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 addtl. employee training for newly identified physical or health hazards ANYTIME during Transition EMPLOYERS, MANUFACTURERS, and DISTRIBUTORS Comply with either HazCom 1994, or HazCom 2012, or both Deadline also applies to EMPLOYERS who choose to perform their own chemical classifications instead of relying on those provided by Mfr/Distr/Imptr

11. 11 Train Employees on: New label elements New safety data sheet format Deadline: December 1, 2013 Why the Rush?

12. 12 Why Train on GHS? Try to think like your employees as you look at these next slides.

13. 13 Why Train on GHS? Do you know what these pictograms mean?

14. 14 Why Train on GHS?

15. 15 Oxidizers Why Train on GHS?

16. 16 Why Train on GHS?

17. 17 Environmental Toxicity Why Train on GHS?

18. 18 Why Train on GHS?

19. 19 Carcinogenicity Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity Aspiration Toxicity Why Train on GHS?

20. 20 Why Train on GHS? Are you familiar with the updated GHS SDS format?

21. 21 How Many Sections in a GHS Formatted SDS? Why Train on GHS?

22. 22 SDS 1.- 2.- 3.- 4.- 5.- 6.- 7.- 8.- 9.- 10.- 11.- 12.- 13.- 14.- 15.- 16.-

23. 23 What Sections Are Outside OSHA’s Jurisdiction? Why Train on GHS?

24. 24 SDS 1.- 2.- 3.- 4.- 5.- 6.- 7.- 8.- 9.- 10.- 11.- 12.Ecological Information 13.Disposal Considerations 14.Transport Information 15.Regulatory Information 16.-

25. 25 In what section of an SDS do you find Hazard(s) Identification info? Why Train on GHS?

26. 26 SDS 1.- 2.Hazard(s) Identification 3.- 4.- 5.- 6.- 7.- 8.- 9.- 10.- 11.- 12.- 13.- 14.- 15.- 16.-

27. 27 Why Train on GHS? How would your employees do answering those same questions?

28. 28 1/11/201328 Examples of What to Cover for December 1, 2013 Training Deadline

29. 29 HazCom 2012 – Preparing for OSHA’s 2013 GHS Training Deadline!

30. 30 Shipped Labels * Standardized under GHS ** Standardized under HCS 1) Product/Chemical Identifier 2) Signal Word 3) Hazard Pictogram(s)* 4) Hazard Statement(s)* 5) Precautionary Statements** 6) Supplier Identifier Six Main Elements

31. 31 1) Product Identifier Name used to identify chemical (e.g., chemical name, code or batch number) Same identifier should also appear in Section 1 of the SDS 2) Signal Word Two Signal words: Danger or Warning Only one will appear, not both – the one representing the most severe hazard Shipped Labels

32. 32 Shipped Labels 3) Hazard Pictogram Harmonized black hazard symbol surrounded by a red diamond border on a white background 8 of 9 adopted – Review each  Environment was not adopted Must contain all elements  No red diamond borders should appear without their respective hazard symbols and vice versa Environmental Toxicity Environment (Not mandatory)

33. 33 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)

34. 34 4) Hazard Statements Define: They describe the nature and degree of hazard associated with a particular chemical Harmonized: So chemicals with same hazards, have same base hazard statements May be combined to reduce redundancies and improve readability Example of a hazard statement: “ Causes damage to lungs through prolonged or repeated exposure when inhaled into lungs.” Shipped Labels

35. 35 5) Precautionary Statements Define what they are i.e., They describe what precautionary measures to take when handling or storing a chemical to prevent or minimize adverse effects resulting from exposure 4 types Prevention, Response, Storage, and Disposal Statements may be combined to save space and improve readability Most stringent statement placed on label Shipped Labels

36. 36 Shipped Labels Acute Toxicity (Fatal or toxic) Acute Toxicity (Harmful) Transient Target Organ Effects Skin & Eye Irritant Dermal Sensitizer Harmful to Ozone Layer (Not mandatory) Exclamation Mark Skull and Crossbones 36 C.2.1.1 of the rule says, If the signal word "Danger" is included, the signal word "Warning" shall not appear; C.2.1.2 of the rule says, “If the skull and crossbones pictogram is included, the exclamation mark pictogram shall not appear where it is used for acute toxicity” Precedence of Hazard Information : SIGNAL WORD Danger OR Warning, NOT both PICTOGRAMS

37. 37 6) Supplier Information Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party Use to contact responsible party with questions related to the chemical and safety Corresponds with contact information in Section 1 – Identification of the SDS Shipped Labels

38. 38 Label producer may provide additional information that it deems helpful” Hazards Not Otherwise Classified (HNOC) PPE pictograms (e.g. HMIS picture of person in goggles) Expiration date, fill date, direction of use Supplemental Label Information

39. 39 Employer is not responsible for updating labels on shipped containers, even if the shipped containers are labeled under HazCom 1994 However, if employer becomes aware of newly identified hazards that are not disclosed on the label, the employer must ensure that workers are aware of the hazards Employer Label Responsibilities

40. 40 Redefined as Safety Data Sheets (SDS) GHS includes 16-part format Essentially the ANSI Standard Several Sections are not Mandatory Sections 12-15 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 = Safety Data Sheets

41. 41 Safety Data Sheets SDS Training - Examples of what to cover Review the 16 sections Heading names Specified order Type of info found in each section Example: 41 Section 6, Accidental Release Measures Lists emergency procedures; protective equipment; proper methods of containment and cleanup

42. 42 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 Safety Data Sheets

43. 43 Describe how information from the SDS relates to the corresponding Shipped Label 43 Shipped Label Safety Data Sheets

44. 44 NOTE: On the SDS, a Pictogram may be represented like: 44 Skull & Crossbones. OR Safety Data Sheets

45. 45 Shipped Label Written Plan Chemical Inventory List Product Identifier same in all 3 places Describe how information on Labels and SDSs relates to your HazCom program and workplace Safety Data Sheets

46. 46 Label Requirements 46 2 Types of Labels with 2 Different Requirements 1) Shipped Container Labels 2) Workplace Container Labels

47. 47 Workplace Labels 47 Requirements for Shipped Label Requirements for Workplace Label Compliance for Workplace Label is still performance-based Compliance for Shipped Label is now more prescriptive

48. 48 Workplace Labeling Compliance Workplace Label System Workplace Label Training Other Info in Workplace 48 Provide employees with immediate access to all hazard information about a chemical

49. 49 Employers Have Four Main Options: 1.Replicate information that is on the manufacturer label 2.Use product identifier and words, pictures, symbols or combination thereof, which + other information immediately available to employee provides specific information regarding hazards 3.Continue to use HazCom 1994 compliant workplace labeling system – so long as employees have information on all health and physical hazards 4.Continue to use NFPA or HMIS systems so long as: Information is consistent with requirements of HazCom Employees have immediate access to specific hazard information and fully aware of hazards of chemicals used Workplace Labeling

50. 50 Workplace Labeling Compliance An OSHA inspector may test for employee comprehension By asking employee look at a container and convey their understanding of the chemical hazards based upon information available as part of the workplace labeling system Employee’s response will dictate whether an employer’s workplace label system is deemed effective 50

51. 51 Employers have to update workplace labels as new information becomes available Labels on Incoming Containers Must not be removed or defaced unless immediately replaced Workplace Labels Must be prominently displayed In English Other languages permitted (additionally) Portable containers No label required for portable containers only intended for immediate use by employee who performs the transfer Workplace Labeling

52. 52 Deadline: June 1, 2015 Manufacturers & Distributors Reclassify chemicals using GHS criteria Produce labels and SDSs in GHS formats Ship updated documents to downstream users with first shipment or next shipment after changes are made Deadline: December 1, 2015 Distributors until this date may ship containers labeled by manufacturer under HazCom 1994

53. 53 “"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.” Two Most Prevalent Changes OSHA added the definition of Classification to the revised standard:

54. 54 “In addition, classification for health and physical hazards includes the determination of the degree of hazard, where appropriate, by comparing the data with the criteria for health and physical hazards.” Two Most Prevalent Changes 2 nd Key Component of the New Definition:

55. 55 UN’s 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

56. 56 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

57. 57 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) Under New OSHA Definition…

58. 58 3 OSHA Specified Hazards - HazCom 2012

59. 59 More info on Classification in Appendices: 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 HCS / HazCom 2012 Appendices

60. 60 Classification

61. 61 Classification

62. 62 Classification

63. 63 Standardization Hazard ClassEU CLPUS OSHA HCS4 th UN GHS Physical Hazards FLAMMABLE LIQUIDS1/2/31/2/3/4 (US Adopted Cat. 4) Environmental Hazards CHRONIC HAZARD TO THE AQUATIC ENVIRONMENT 1/2/3/4Not Required1/2/3/4 63

64. 64 In-House or Outsource? Should We Author In-House? Already Setup Not Currently Setup Is your current software updated to meet GHS criteria? What do we need to do to be set up to author internally? Consider Overhead and staffing needs Training needs IT commitments Can it be updated in time? Cost? Consider Procure software (local or cloud?) IT commitments for installation Overhead costs Training Costs Benefits Consider Capacity Desired service level Pricing Per document + hourly rate Straight hourly rate All inclusive per document rate Project timeline considerations Should We Outsource? What are the considerations when selecting an authoring service provider?

65. 65 Employers Must Complete any necessary HazCom program updates, including updates to the written plan and the chemical inventory list Update workplace labels as necessary Complete training on any newly identified hazards resulting from manufacturer chemical reclassifications Be using the updated versions of SDSs and labels Written Plan Chemical Inventory List Training Labels Deadline: June 1, 2016

66. 66 HCS Employer Responsibilities Written HazCom Plan Employee Training Chemical Inventory Labels & Warning Signs Safety Data Sheets

67. 67 Employees Trained: On chemicals present in their work areas On location of written HazCom program, list of chemicals, and MSDSs Before working with a hazardous chemical & whenever a new hazard is introduced into their work area On detecting presence/release of a hazardous chemical in the work area On specific chemicals or categories of hazards (e.g., flammability, carcinogenicity) Training must be Effective - Employees must carry the knowledge into their daily jobs General HazCom Training Expectations

68. 68 Identify Training Needs Task Analysis Who trained on what? Learning outcomes Recognition Discrimination Understanding Skills Population Considerations Age and length of service Educational level Language differences Resource Considerations Budget Location & shift work

69. 69 Task Analysis / What: How many different chemical classes/substances are there in the work areas? Which chemical hazards are involved? How many different job classifications? How many employees in each classification? How often are new processes involving chemical hazards introduced? How often do you expect to receive new MSDSs? Do you have any potentially hazardous chemicals in non-labeled pipes? What General Elements are needed? What site-specific training is needed? What learning outcomes are needed? Information to be made available? Knowledge? Skills? Identify Training Needs

70. 70 Population Considerations / Who: What is the size of the group to be trained on any one topic? How many different groups do you have? What are the average ages of employees within the defined groups? What length of service? What is the rate of turnover (new hires, transfers)? What educational levels? Are there reading or learning difficulties? Are there language differences? How much work experience within groups? Is there any documentation of prior training? Identify Training Needs

71. 71 Resource Considerations / How? What is your budget? Do you have a room large enough to handle your groups? Do you have other options? What assistance will be available? What kinds of audiovisual aids are available? What existing programs might be used? What problems might you have in arranging the training (i.e., scheduling)? How will you handle the training of shift workers? Identify Training Needs

72. 72 1.Observable: Employees must be able to demonstrate learning 2.Measurable: Objectives should define acceptable performance 3.Performance Conditions Stated: Conditions under which the individual will demonstrate competence Setting Training Objectives

73. 73 Good Examples: Given an MSDS, employee will correctly locate at least three pieces of designated information Employee will list correctly the three steps to take in reporting a leak or spill Bad Example Worker will understand the hazards of chemicals with which he or she works Setting Training Objectives

74. 74 There is no requirement to document training OSHA recommends that you do – encourages recording the following: 1.Date of presentation 2.Learning objectives 3.Training program outline 4.Names of participants, with an identifier such as Social Security number 5.Names of instructors 6.Data, such as test results, to demonstrate that objectives were met Paper copies of training records are hard to maintain, consider inexpensive and user-friendly software. Retrain when employees are no longer retaining their hazard communication knowledge and skills Documenting Training

75. 75 Retraining OSHA has no specific retraining requirement Retrain when employees are no longer retaining their hazard communication knowledge and skills You don’t have to repeat the entire hazard communication training program if you can document that some or most knowledge and skill concepts have been retained Documenting Training

76. 76 14 Steps Towards Employer Compliance

77. 77 1.Designate GHS Transition Leader 2.Get Educated on GHS 3.Inventory Chemicals (Physical Inventory) 4.Check Inventory Against Safety Data Sheet Library 5.Acquire Missing MSDSs 6.Safely Dispose of Chemicals No Longer in Use/Needed 7.Archive MSDSs No Longer Used 8.Train Employees on GHS Label Elements and SDS Format 9.Prepare for SDS Churn a)Look for new hazards on incoming safety data sheets 10.Get Secondary Container Labeling Strategy 11.Train Employees On Any New Hazards 12.Update Written HazCom Program 13.Meet SARA / EPCRA Reporting Obligations 14.Stay Current on GHS Employer Compliance Tasks

78. 78 GHS Alignment Timeline http://www.msdsonline.com/ blog/ghs-compliance- checklist/

79. 79 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 Penalties for Noncompliance Are Very Real Source: www.OSHA.gov

80. 80 Fines Potential Risk & Liability Downtime & Internal Disruption Lost Revenues Negative Press & Impact to Corporate Image Costs Add Up Quickly

81. 81 Electronic Management OSHA’s provisions for electronic MSDS management and deployment, haven’t changed Electronic systems are still permitted under HazCom 2012, so long as there is: No barrier preventing employee access to the SDSs, A compliant back-up system is in place for retrieving SDSs during foreseeable emergencies like power-outages, Hard copies of SDSs can be provided upon request Employers want to be sure they understand how their electronic system will go about handling the MSDS to SDS document churn 81 OK Still OK

82. 82 Links to GHS Info http://www.MSDSonline.com http://www.MSDSonline.com/blog/ghs-answer-center/ http://www.MSDSonline.com/blog/ghs-101-links-to-useful-ghs- information/

83. 83 Questions 1.888.362.2007 www.MSDSonline.com sales@MSDSonline.com bharbaugh@MSDSonline.com