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Bill Balek ISSA July 31, 2013 GHS HazCom Training
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GHS HazCom Training Today’s Session Employee Education and Training
Revised OSHA Hazard Communication Standard Due Dec. 1, 2013 Background March 20, 2012: OSHA issues final rule GHS revisions to Hazard Communication Standard
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GHS HazCom Training Background OSHA HCS Governs:
Chemicals MSDSs Labels Employee education and training Purpose: Avoid chemical injury and illnesses
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GHS HazCom Training Background 1985: OSHA issues HCS
Labeling, MSDS for hazardous chemicals 2001: Globally Harmonized System of Classification and Labeling of Chemicals (GHS) UN members agree to adopt GHS by 2008 2012: GHS Revisions to HCS
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GHS Rev’s to OSHA HCS Overview
What remains the same under GHS Rev’s? Basic structure Manufacturers: Classify chemicals and provide SDS, labels to downstream customers Distributors: Pass SDS and labels downstream Employers: Employee education and training Avoid chemical injuries and illnesses
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GHS Rev’s to OSHA HCS Overview
What’s changed? Tactics. Classification of hazards (Manufacturer) SDS: redraft to comport with new format, pictograms, etc. (Manufacturer) Labeling (Manufacturer) More prescriptive, uniform language Pictograms
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GHS Rev’s to OSHA HCS Implications for Cleaning industry
Chemical Manufacturers Distributors Cleaning Service Providers
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GHS Rev’s to OSHA HCS Implications for Chemical Manufacturers
Obligations that run to downstream customers Re-classify products Re-draft SDSs Re-do labels June 1, 2015
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GHS Rev’s to OSHA HCS Implications for Distributors
Obligations that run to downstream customers Send new GHS SDS (June 1, 2015) Ship products with new GHS labels (Dec. 1, 2015)
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GHS HazCom Training Implications for “Employers”
Employers: Manufacturers, Distributors, Cleaning Service Providers Employee education and training New label elements New SDS format Dec. 1, 2013
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GHS HazCom Training New Labeling Elements Effective June 1, 2015
Distributors Dec. 1, 2015 Permissible to comply earlier
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GHS HazCom Training Safety Data Sheets (SDS)
Formerly MSDS New 16 section uniform format Effective June 1, 2015 Permissible to comply earlier
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GHS Rev’s to OSHA HCS Workers may see GHS labels, SDS soon…
OSHA requires employee training New label elements New SDS format Dec. 1, 2013 Ensure workers have info to protect themselves Understand GHS labels and SDS
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New Labeling Elements Product identifier Signal word Hazard statement
Pictograms Precautionary statement(s) Name, address, telephone number of manufacturer or other responsible party
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New Labeling Elements Signal word Hazard statement Pictograms
Harmonized label elements Based on hazard class and hazard category In general, manufacturer has no discretion
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New Labeling Elements Product identifier Signal word Name of product
Same as on SDS Signal word Indicates severity of hazard Danger: more severe hazards Warning: less severe hazards Only one signal word on the label Not all hazards have signal words
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New Labeling Elements Hazard statement
Describes the nature of the hazard “Causes skin irritation” “Flammable liquid and vapor” All applicable hazard statements must be on label Uniform (mandatory Appendix C)
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New Labeling Elements Pictograms Images that communicates the hazard
Square on point Black hazard symbol White background Red border Red border minus hazard symbol NOT allowed
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Pictograms Skin corrosion, burns Eye damage Corrosive to metals
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Pictograms Flammable Pyrophorics Self-heating Emits flammable gas
Self-reactive Organic peroxides
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Pictograms Oxidizer Gases under pressure
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Pictograms Carcinogen Mutagenicity Reproductive toxicity
Respiratory Sensitizer Target organ toxicity Aspiration toxicity
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Pictograms Explosives Self-reactives Organic peroxides
Acute toxicity (fatal or toxic)
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Pictograms Irritant (skin, eye) Skin sensitizer Acute toxicity
Narcotic effects Respiratory tract irritant Hazardous to ozone layer Aquatic toxicity Non-mandatory
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New Labeling Elements Precautionary Statements
Recommended measures to prevent or minimize adverse effects from exposure , improper storage or handling What to do to prevent harmful exposure Wash thoroughly after handling Wear protective gloves What to do if there is harmful exposure If eye irritation persists, get medical advice
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New Labeling Elements Name, address, telephone number of manufacturer or other responsible party Address City and state sufficient Telephone number New requirement
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New Labeling Elements XYZ Cleaner XYZ Manufacturing Co. Chicago, IL
Pictogram Product Identifier Signal Word XYZ Cleaner Warning XYZ Manufacturing Co. Chicago, IL Causes serious eye irritation Hazard Statement Wash hands thoroughly after handling. Wear eye protection. Store in a cool dry place. First Aid If in eyes, rinse cautiously with water for several minutes. Remove contact lenses, if present, and easy to do. Continue rinsing. If eye irritation persists: get medical attention. Manufacturer Precautionary Statement
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New Labeling Elements Make sure employees know…
How to go from label to SDS How to use label to Properly store product Work with product safely Avoid harmful exposure What to do in event of harmful exposure Where product has multiple hazards Multiple pictograms, hazard statements
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New SDS Format Standardized 16-section format
SDS must be presented in a consistent order Sec. 1: Identification Product identifier used on label Recommended use of the chemical Name, address and telephone number of manufacturer, importer or other responsible party Emergency phone number
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New SDS Format Standardized 16-section format
Sec. 2: Hazard identification Hazard class, and category (i.e., flammable liquid, category 4) Label elements: Signal word (i.e., Warning) Hazard statement (i.e., combustible liquid) Pictograms (none for flammable liquid, cat. 4) Precautionary statement Consistent with label / “Heart” of SDS
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New SDS Format Standardized 16-section format
Sec. 3: Composition/information on ingredients Information on chemical ingredients, trade secrets Sec. 4: First-aid measures Description of measures based on route of exposure Immediate medical treatment Sec. 5: Fire fighting measures Suitable and unsuitable extinguishing media Special hazards presented by the chemical in fire
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New SDS Format Standardized 16-section format
Sec. 6: Accidental release measures Personal precautions, emergency procedures Sec. 7: Handling and storage Precautions for safe handling and storage Any incompatibilities Sec. 8: Exposure controls / personal protection OSHA PELs, TLVs Appropriate engineering controls (ventilation PPE
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New SDS Format Standardized 16-section format
Sec. 9: Physical and chemical properties Appearance, pH, odor, flash point, vapor pressure, etc. Sec. 10: Stability and reactivity Chemical stability, possibility of hazardous reactions Conditions to avoid, incompatible materials Sec. 11: Toxicological information Routes of exposure, related symptoms, acute and chronic effects
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New SDS Format Standardized 16-section format
SDS must contain sections 12-15, but… OSHA will not enforce the content for these Sections Sec. 12: Ecological information Sec. 13: Disposal considerations Sec. 14: Transportation information Sec. 15: Regulatory information Sec. 16: Date of preparation, last revision
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GHS HazCom Training Info must be presented in manner workers can understand Non-english speaking workers Illiterate Recommend: Keep record of employees trained Sign in log Training materials used Tests
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GHS HazCom Training If you would like a certificate indicating you have been trained consistent with the GHS HazCom Training requirements… Subject Line: CERTIFICATE Short Test Upon passing test, certificate will be issued
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GHS HazCom Training ISSA Resources
Detailed Summary: Manufacturers: Formulator Webinar Series Reclassification, SDS, Labels Formulator Webinar Employee Education and Training (Dec. 1, 2013) Webinar: July 31 Online training: Resources:
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Thank You! Questions??? Bill Balek, ISSA
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