1. PMAA OSHA REVISED HAZARD COMMUNICATION STANDARD 29 CFR 1910.1200

2. HAZCOM OVERVIEW
Compliance with OSHA hazardous communication standard (HCS) has been required since 1983.
OSHA recently revised the HCS requirements to harmonize with international standards.
HCS provides employees the right-to-know the hazards and identities of the chemicals they are exposed to in the workplace.
Employers must disclose to empl0yees information about the presence and nature of hazardous chemicals in workplace through access to container warning labels, safety data sheets and written HAZCOM plan.
Employers must train employees how to recognize and understand OSHA chemical hazard information.

3. HAZCOM OVERVIEW
Petroleum manufacturers (refiners, terminal operators) must provide petroleum distributors new safety data sheets (SDS) for hazardous chemicals (petroleum products)to replace current material safety data sheets (MSDS).
Petroleum distributors must provide new SDS to retailers.
Petroleum distributors and retailers are “employers” and must provide employees with access to SDS and have a written HCS program.
Petroleum distributors and retailers must train employees how to recognize and understand information on hazardous chemical labels and SDS.
Petroleum distributors and retailers must label all hazardous chemical containers (including stationary ASTs and skid tanks) with new OSHA HCS labels.
Petroleum retailers must provide SDS to customers upon request only.

4. WHY THE CHANGES?
OSHA changed the workplace hazard communication standard to align with international standards.
Globally Harmonized System of Classification and Labeling of Chemicals (GHS) adopted by 67 nations.

5. WHICH HCS REQUIREMENTS ARE CHANGING?
Material Safety Data Sheet name and format.
16 new hazard information sections.
Chemical container label information and format.
New pictograms.
Signal words.
Hazard statements.
Precautionary statements.
Product information.
Suppler/manufacturer identification.

6. WHO MUST COMPLY? Chemical Manufacturers, Importers Change SDS format.
Change Container label format.
Petroleum Distributors:
Must pass down new SDS to all customers who are employers on first delivery.
Petroleum Distributors and Retailers:
Must train employees on new SDS sheets and container labels.

7. WHO MUST BE TRAINED?
Only employees working in areas where hazardous chemicals are present must be trained.
Work area means a room or defined space in a workplace where hazardous chemicals are produced or used, and where employees are present.
Workplace means an establishment, job site, or project, at one geographical location containing one or more work areas.
Employees just passing through but not assigned to the work area need not be trained.

8. WHO MUST BE TRAINED?
Anyone working directly in the presence of hazardous chemicals in the workplace that pose a risk for the employee’s health and/or environmental hazard. (very subjective).
Drivers at loading racks.
Lube 0il warehouse.
Car wash employees.
C-store employees.
HVAC Service technicians.

9. WHAT KIND OF TRAINING? Training must be such that employees:
Recognize and understand hazards of chemical based on information in the 16 new sections of the SDS format.
Recognize and understand pictograms, precautionary statements, signal words, hazard statements, product identification and identity of manufacturer on container shipping label.

10. WHEN IS TRAINING REQUIRED?
Upon initial employment.
When a new hazardous product/chemical is introduced into the workplace.
Change in process.
As deemed necessary by supervisor/management.

11. COMPLIANCE DATES
Both petroleum marketer distributors and retailers must update their written hazard communication program, workplace container labeling (skid tanks and stationary above ground bulk tanks included), train employees concerning the OSHA HCS revisions (labels and SDS) no later than June 1, 2016.
Petroleum marketer distributors should supply retailers with new SDS as soon as they become available from upstream suppliers but no later than June 1, Chemical manufacturers were required to provide the new SDS to downstream distributors by June 1, 2015.

12. NEW CONTAINER LABELS
Container means any bag, barrel, bottle, box, can, cylinder, drum, storage tank, or the like that contains a hazardous chemical.
Portable skid tanks and stationary above ground storage tanks must be labeled.
Cargo tank vehicles are not required to have OSHA labels.
Fuel tanks or other operating systems in a vehicle do not need to be labeled in accordance with this standard as they are not considered containers.
Liquid propane (LP) cylinders for delivery must be labeled.

13. NEW CONTAINER LABEL ELEMENTS
9 new Symbols called “pictograms”.
Signal Words.
Hazard Statements.
Precautionary Statements.
Product Identification.
Supplier/Manufacturer Identification.
Supplementary Information.
This is an example of the new label style that is to appear on product labels beginning no later than June 1, 2015 (or Dec. 1, 2015 for distributers who still have product in inventory after the June 1, 2015 deadline).
The type of required information is noted in blue. The actual statements and information will vary depending on the specific health and physical classification of the product.

14. LABEL PICTOGRAMS There are 9 pictograms in three hazard categories:
Health Hazards.
Physical Hazards.
Environmental Hazards.
There are 3 pictograms specific to health hazards: exclamation, health hazard (silhouette of a person with starburst on the chest) and skull and crossbones.
There is 1 pictogram that can represents both physical and/or health hazard of corrosive.
There are 4 pictograms specific to physical hazards: exploding bomb, flame, flame over circle (oxidizer) and gas cylinder.
There is 1 for environment: Environmental Hazards are not regulated by MIOSHA. Check with the Michigan Department of Environmental Quality (DEQ) for any employee training requirements for these sections. DEQ Environmental Assistance Center can be reached at (800) from 8 a.m. to 4:30 p.m., Monday through Friday or

15. LABELS: PICTOGRAMS – HEALTH HAZARDS
Describes:
Acute toxicity (Severe)
Describes:
Acute toxicity (Less Severe):
Irritant
Dermal sensitizer
Acute toxicity (harmful)
Narcotic effects
Respiratory tract irritation

16. LABELS: PICTOGRAMS – HEALTH HAZARDS
Carcinogen
Respiratory sensitizer
Reproductive toxicity
Target organ toxicity
Mutagenicity
Aspiration Hazard
Skin corrosion
Serious eye damage/
Eye irritation

17. LABELS: PICTOGAMS -PHYSICAL HAZARDS
Flammables
Self reactives
Pyrophorics
Self heating
Emits flammable gas
Organic peroxides
Explosives
Self reactives
Organic peroxides

18. LABELS: PICTOGRAMS – PHYSICAL HAZARDS
Corrosive to Metals
Oxidizer
Gases under Pressure

19. LABELS: PICTOGRAM - ENVIRONMENTAL HAZARD

20. U.S. DOT SHIPPING LABELS PICTOGRAMS MAY BE USED
Flammable Liquid Flammable Gas Flammable Aerosol
Flammable solid Self-Reactive Substances
Pyrophorics (Spontaneously Combustible) Self-Heating Substances
Substances, which in contact with water, emit flammable gases (Dangerous When Wet)
Oxidizing Gases Oxidizing Liquids Oxidizing Solids
Explosive Divisions 1.1, 1.2, 1.3
Explosive Division 1.4
Explosive Division 1.5
Explosive Division 1.6
Compressed Gases
Acute Toxicity (Poison): Oral, Dermal, Inhalation
Corrosive
Marine Pollutant
Organic Peroxides

21. LABEL SIGNAL WORDS
Only two signal words are used to indicate the severity of the hazard and alert employees to the potential hazard.
“DANGER” more severe hazard).
“WARNING” (less severe hazard).
Not all labels will have a signal word. Some chemicals are not hazardous enough to require that a signal word appear on the label.

22. LABEL -HAZARD STATEMENT
There are specific hazard statements that must appear on the label based on the chemical hazard classification. Examples:
Flammable liquid and vapor.
Causes skin irritation.
May cause cancer.

23. LABEL – PRECAUTIONARY STATEMENT
Recommended measures related to:
Prevention.
Response.
Storage.
Disposal.
Examples:
Wear respiratory protection.
Wash with soap and water.
Store in a well ventilated place.
Not a mandate for employers/employees to follow.

24. LABEL – PRODUCT IDENTIFICATION
Product identification (i.e. name OR number the of product).

25. LABEL - MFG/SUPPLIER IDENTIFICATION
The following manufacturer and/or supplier identification must be on label:
Address.
Telephone number.
Use batch label , name address and phone number for multiple manufacturers.

26. LABEL – OTHER INFORMATION
Other information that may be included on the label at the discretion of manufacturer or distributor:
Physical state.
Color.
Hazards not otherwise classified.
Route of exposure.
Storage and disposal.
Hazard prevention and,
Emergency response instructions.

28. ALTERNATIVE CONTAINER LABELS
Repackaging hazardous chemicals. Employers must label repackaged containers with either:
GHS Label; or
Alternative label that:
Is consistent with the revised HAZCOM standard.
Does not have conflicting hazard warnings or pictograms.
Example: NFPA Label must include OSHA notation of chronic health effects. NFPA does not allow altering the white diamond within the larger diamond.
Product Identifier = name or number unique to the chemical listed on the manufacturer label or in SDS.
Note: waste container labeling requirements are covered under EPA/DEQ rules. Contact DEQ for additional information.

29. SAFETY DATA SHEETS Safety Material Data Safety Sheets Data Sheets
What’s New?
Name –Now called “Safety Data Sheet” (SDS).
Format -All SDSs will have a consistent 16-section format.
Safety
Data
Sheets
Material
Safety
Data
Sheets

30. NEW 16 SECTION SDS FORMAT
Section 1 – Identification Section 2 – Hazard(s) identification Section 3 – Composition / Information on Ingredients Section 4 – First-aid Measures Section 5 – Fire-fighting Measures Section 6 – Accidental Release Measures Section 7 – Handling and Storage Section 8 – Exposure Controls / Personal Protection Section 9 – Physical and Chemical Properties
Section 10 – Stability and Reactivity Section 11 – Toxicological Information Section 12 – Ecological Information Section 13 – Disposal Consideration Section 14 – Transport Information Section 15 – Regulatory Information Section 16 – Other information including date of preparation of last revision

31. SDS FORMAT SECTIONS Section 1 – Identification:
Identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier.
Section 2 - Hazards Identification:
Hazards of the chemical presented on the SDS
Appropriate warning information associated with those hazards.

32. SDS FORMAT SECTIONS Section 3 – Composition / Ingredients:
Identifies the ingredient(s) contained in the product indicated on the SDS, including:
Impurities and stabilizing additives.
Information on substances, mixtures, and all chemicals where a trade secret is claimed.
Section 4 - First-Aid Measures:
Describes the initial care that should be given by untrained responders to an
individual who has been exposed to the chemical.

33. SDS FORMAT SECTIONS
Section 5 – Fire-Fighting Measures: Provides recommendations for fighting a fire caused by the chemical. Section 6 - Accidental Release Measures: Provides recommendations for appropriate response to spills, leaks, or releases, (e.g. containment and cleanup practices).

34. SDS FORMAT SECTIONS
Section 7 – Handling and Storage: Provides guidance on the safe handling practices and conditions for safe storage of chemicals. Section 8 – Exposure Controls / Personal Protection: Indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure.

35. SDS FORMAT SECTIONS
Section 9 – Physical and Chemical Properties: Identifies physical and chemical properties associated with the substance or mixture. Section 10 – Stability and Reactivity: Describes the reactivity hazards of the chemical and the chemical stability information.

36. SDS FORMAT SECTION
Section 11 - Toxicological Information: Identifies toxicological and health effects information or indicates is data unavailable. Section 12 – Ecological Information Identifies release pathways and subsequent environmental harm. Section 13 – Disposal Consideration Identifies proper method of disposal.

37. SDS FORMAT SECTION
Section 14 – Transport Information Identifies U.S. DOT hazard description. Section 15 – Regulatory Information Federal law citation that regulates the hazardous chemical. Section 16 – Other Information Indicates when the SDS was prepared or when the last known revision was made. The SDS may also state where the changes have been made to the previous version.

38. SAMPLE SAFET DATA SHEETS
WARNING!
THE FOLLOWING SAFETY DATA SHEET SAMPLES ARE FOR ILLUSTRATION ONLY. DO NOT REUSE.
SDS WILL VARY BETWEEN BRAND AND SUPPLIER.

43. EMPLOYEE ACCESS SDSs, safety labels and written HAZCOM plan:
Must be readily accessible to employees during their work shift.
Are typically kept in a centralized location.
Must be updated as new information becomes available.
Computerized files are ok so long as employee has access.

44. WRITTEN HAZARD COMMUNICATION PLANS
The HCS requires all workplaces where employees are exposed to hazardous chemicals to have a written plan.
A written hazard communication plan describes how the facility will implement the revised HCS standard.
The plan does not have to be lengthy or complicated. It is intended to be a blueprint for implementing your program -- an assurance that all aspects of the requirements have been addressed.
The written program must describe how the requirements for labels and other forms of warning, materials safety data sheets, and employee information and training, are being met.
A written hazard communication template is attached.

45. BOTTOM LINE Both petroleum marketers and petroleum retailers must:
Train employees on how to recognize and understand new HCS labels and safety data sheets.
Provide access to HCS information including SDS, labels in a central HCS file.
Revise existing OSHA written hazardous communication program.
Affix new revised OSHA HCS labels on workplace containers of hazardous chemicals including stationary above ground storage tanks and skid tanks.
Petroleum Distributors must provide retailers and other customers who are employers a copy of new SDS for each petroleum product delivered on first delivery and when SDS changes