1. Protecting Employees from Workplace Hazards
OSHA Hazard Communication & Occupational Exposure to Hazardous Chemicals in Laboratories

2. Introduction Presenter - Colleen Cunanan, AKOSH Industrial Hygienist
Purpose – familiarize you with OSHA’s Hazard Communication & Occupational Exposure to Hazardous Chemicals in Laboratories Standards [CFR & ]

3. Overview Hazard Communication Standard (HCS)
2012 standard revision to incorporate the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS)
Requirements of the standard
Occupational Exposure to Hazardous Chemicals in Laboratories Standard (Lab Standard)
Comparison of the Lab Standard to HCS

4. OSHA’s Hazard Communication Standard
29 CFR

5. What is Hazard Communication?
OSHA Hazard Communication Standard 29 CFR – “Right to Know” went into effect in November 1985
The purpose of Hazcom is to communicate workplace chemical hazards and appropriate protective measures to employees
Employees have a Right to Know about the hazards in their work areas and the potential effects of these hazards upon their health and safety
43 million workers are exposed to hazardous chemicals in over 5 million workplaces (OSHA, Modification…GHS 2012)
575,000 hazardous chemical products in these workplaces (NIOSH 48 FR 53323)

6. What is Global Harmonization?
A common and coherent approach to defining and classifying hazards, and communicating information on labels and safety data sheets
Provides the underlying infrastructure for establishing a national, comprehensive chemical safety program
The new hazard communication standard still requires chemical manufacturers and importers to evaluate the chemicals they produce or import and provide hazard information to employers and workers by putting labels on containers and preparing safety data sheets. However, the old standard allowed chemical manufacturers and importers to convey hazard information on labels and material safety data sheets in whatever format they chose. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets.

7. How will Global Harmonization help?
Improve comprehensiveness
Improve consistency
Improve understanding
Many countries have regulations regarding the dissemination of information on chemical hazards. While similar, they are different enough to require multiple labels and safety data sheets for the same product traded internationally.
GHS is intended to aid in communication. Based on the following principles:
Information should be conveyed in more than one way.
Phrases used to indicate degree of severity should be consistent across different hazard types.

8. Changes to HCS Hazard Classification Labels Safety Data Sheets
Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result.
Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
Safety Data Sheets: Will now have a specified 16-section format.

9. Timeline for Compliance
Effective Completion Date
Requirement(s)
Who
December 1, 2013
Train employees on the new label elements and safety data sheet (SDS) format.
Employers
June 1, 2015*
December 1, 2015
Compliance with all modified provisions of this final rule, except:
The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label
Chemical manufacturers, importers, distributors and employers
June 1, 2016
Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
Transition Period to the effective completion dates noted above
May comply with either 29 CFR (the final standard), or the current standard, or both
Chemical manufacturers, importers, distributors, and employers

10. Key Elements of the Hazard Communication Standard (HCS)
Written Program – must be developed and tie all the following elements together
Training - all employees must be trained to identify and work safely with hazardous materials
Labeling - containers of hazardous materials must have labels which identify the material and warn of its potential hazard to employees
Safety Data Sheets (SDSs) - detailed description of each hazardous material present in the workplace

11. HCS Written Program
Information and training the employee will receive regarding workplace hazards
Labeling and other forms of warning utilized in the workplace
Maintenance of SDSs for every chemical
Chemical inventory
Methods the employer uses to inform employees of hazards of non-routine tasks and hazards of chemicals in unlabeled pipes in work areas
Methods of communicating hazards to other employers (contractors)

12. Additional Alaska Requirements
Chemical inventory with locations
Physical Agent Data Sheets (PADs)
Table Z-1-A
Example - Acetone
Fed PEL – TWA 1000 ppm
AK PEL – TWA 750 ppm, STEL 1000 ppm
Per Alaska statute (8 AAC (f)(3)), employer must post a list of the chemical name/product name of any toxic or hazardous substance and physical agent with an identification of workplace location
Per Alaska statute (8 AAC (a)), employer must have PADs for any physical agent present at workplace. Information and training must be provided upon initial assignment and whenever a new physical agent is introduced to their work area.
Alaska has more stringent PELs than Fed OSHA. A copy should be included in SDS binder as SDSs typically list only the Fed OSHA limits.

13. HCS Training Requirements
Employee training is an integral part of the hazard communication program and must be provided:
At the time of initial assignment
Whenever a new hazard is introduced into the workplace, and
When employees may be exposed to other employers’ workplace hazards
Hazard Communication – Site specific training
Details of employer’s Hazcom program
Specific hazards in the workplace
Methods to detect presence or release of a hazardous chemical
Methods to reduce hazards - product substitution, engineering controls, administrative controls, and personal protective equipment

14. Training – Non-routine Tasks
Prior to starting work on such projects, affected employees will be given information on hazards to which they may be exposed during such activity
This information will cover:
Specific hazards
Measures the employer has taken to reduce the risk of these hazards
Required protective/safety measures
Measures to reduce risk of hazards could include ventilation, ensuring presence of another employee, providing a respiratory protection program, and establishing emergency procedures.

15. Labels Warn of potential hazards
Not intended to be the only source of information
Serve as an immediate warning

16. What must be labeled?
The OSHA Hazard Communication Standard requires that ALL hazardous materials be labeled. Labels must appear either on the container itself, a batch ticket, placard, or process sheets
Hazardous chemicals in portable containers which are for the immediate use of the employee who performs the transfer is the exception to this rule

17. Manufacturer/Importer Label Requirements
Product identifier
Signal word
Hazard statement
Pictograms
Precautionary statements
Name, address, and phone number of responsible party
Under the current Hazard Communication Standard (HCS), the label preparer must provide the identity of the chemical, and the appropriate hazard warnings. This may be done in a variety of ways, and the method to convey the information is left to the preparer. Under the revised HCS, once the hazard classification is completed, the standard specifies what information is to be provided for each hazard class and category. Labels will require the following elements:
Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards.
Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the HCS.
Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical.

18. GHS Pictograms and Hazards
Health Hazard
Flame
Exclamation Mark
• Carcinogen • Mutagenicity • Reproductive Toxicity • Respiratory Sensitizer • Target Organ Toxicity • Aspiration Toxicity
• Flammables • Pyrophorics • Self-Heating • Emits Flammable Gas • Self-Reactives • Organic Peroxides
• Irritant (skin and eye) • Skin Sensitizer • Acute Toxicity (harmful) • Narcotic Effects • Respiratory Tract Irritant • Hazardous to Ozone Layer (Non Mandatory)

19. GHS Pictograms and Hazards
Gas Cylinder
Corrosion
Exploding Bomb
• Gases under Pressure
• Skin Corrosion/ burns • Eye Damage • Corrosive to Metals
• Explosives • Self-Reactives • Organic Peroxides

20. GHS Pictograms and Hazards
Flame Over Circle
Skull & Crossbones
Environment (Non-mandatory)
• Oxidizers
• Acute Toxicity (fatal or toxic)
• Aquatic Toxicity

21. GHS Compliant Label

22. Workplace Labeling
Standard is “performance based” – allows flexibility in labeling system
Employers may use NFPA, HMIS, or duplicate the shipped label (GHS)
Allowed labeling must be consistent with HCS, no conflicting hazard information
Employer must ensure each container of hazardous chemicals is labeled

23. Workplace Labeling Must include:
Product identifier – must match SDS and chemical inventory
Words, pictures, symbols or combination of these that will provide employees with specific information regarding the physical and health hazards
Allowed labeling must be consistent with HCS, no conflicting hazard information
Employer must ensure each container of hazardous chemicals is labeled

24. Workplace Labeling
Ensure labels are not removed, defaced, or unreadable
For hard to label containers use:
Signs or placards
Process sheets or batch tickets

25. Safety Data Sheets (SDSs)
Formerly referred to as Material Safety Data Sheets (MSDSs)
SDSs provide detailed health and safety information and precautions for handling hazardous substances, including emergency and first aid procedures
Employer must have a SDS for each hazardous chemical in the workplace and ensure SDSs are accessible to all employees

26. SDS Requirements HCS requires a standardized 16 section format
1. Identification 2. Hazard(s) Identification 3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling and storage 8. Exposure controls/personal protection
9. Physical and chemical properties 10. Stability and reactivity 11. Toxicological information 12. Ecological information 13. Disposal considerations 14. Transport information 15. Regulatory information 16. Other information
All sections are required for SDS to be consistent with GHS but OSHA will not enforce content of sections since they are not under jurisdiction
Sigma aldrich SDS example:

27. PADs – Alaska Requirement
Cold Stress
Hand-Arm Vibration
Heat Stress
Ionizing Radiation
Lasers
Noise
Radio Frequency/Microwave Radiation
Ultraviolet Radiation
PADs are available on the AKOSH website

28. OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories
29 CFR

29. Key Elements of the Lab Standard
Scope – laboratory use of chemicals; supersedes other subpart Z requirements except:
PEL limitations
Skin and eye contact prohibition
Monitoring/medical surveillance requirements
Written chemical hygiene plan – defines how employees will be protected and exposures will be kept below PELs
Training – all employees must be trained on chemical hazards
Medical consultation and examinations – provided free to employee by licensed physician under certain circumstances
Hazard identification – labels and SDSs

30. What is “laboratory use” of chemicals?
Chemical manipulations are carried out on a “laboratory scale”;
Multiple chemical procedures or chemicals are used;
Procedures involved are not part of a production process, nor in any way simulate a production process; and
“Protective laboratory practices and equipment” are available and in common use to minimize the potential for employee exposure to hazardous chemicals.
Laboratory scale = work with substances in which the containers used for reactions, transfers, and other handling of substances are designed to be easily and safety manipulated by one person. Excludes those workplaces whose function is to produce commercial quantities of materials.
Protective laboratory practices and equipment = procedures, practices and equipment accepted by laboratory health and safety experts as effective, or that the employer can show to be effective, in minimizing the potential for employee exposure to hazardous chemicals.

31. Written Chemical Hygiene Plan (CHP)
Must be:
Capable of protecting employees from health hazards associated with hazardous chemicals in laboratory
Capable of keeping exposures below PELs
Readily available to all employees

32. Required CHP Elements
SOPs for work involving use of hazardous chemicals
Criteria to determine and implement control measures to reduce employee exposure
Requirement that fume hoods and other protective equipment are functioning properly and measures taken to ensure adequate performance of such equipment

33. Required CHP Elements Provisions for training and information
Procedures requiring prior approval
Provisions for medical consultation and examination
Responsible personnel – Chemical Hygiene Officer
Provisions for additional employee protection when working with particularly hazardous substances

34. Lab Standard Information and Training Requirements
Employees must be apprised of hazards of chemicals present in their work areas
Must be provided at time of initial assignment and prior to assignment involving new exposure situation

35. Lab Standard Information and Training Requirements
Employees must be informed of:
Contents of and appendices
Location of employer’s CHP
PELs
Signs and symptoms of exposure to chemicals in the laboratory
Location of reference materials such as SDSs

36. Lab Standard Information and Training Requirements
Employee training must include:
Methods and observations that may be used to detect presence or release of hazardous chemical
Physical and health hazards of chemicals in the work area
Measures employees can take to protect themselves such as appropriate work practices, emergency procedures, and personal protective equipment (PPE)

37. Medical Consultation and Examinations
Opportunity shall be provided when:
Signs/symptoms shown
Monitoring indicates need
An “event” results in likelihood of exposure
Shall be followed by Dr’s written opinion
Requires the employer provide info to Dr
Shall be:
At no cost to employee
Provided by a licensed physician
Must be provided by a licensed physician, be free or charge, without loss of pay and at a reasonable time and place.
Physician should be informed of chemical exposed to, conditions under which the exposure occurred, and the signs and symptoms the employee is experiencing.
Physician will provide employer with written opinion with recommendations for follow-up exams, results of the exam and any tests, medical conditions revealed that may place the employee at increased risk as a result of chemical exposure. The written opinion will not disclose any findings unrelated to the occupational exposure.

38. Hazard Identification
Labels on incoming containers shall not be removed or defaced
SDSs received with incoming shipments of hazardous chemicals must be maintained and be made readily accessible

39. Hazard Identification
Chemicals developed in lab:
If composition is known, employer must determine if it is hazardous and provide appropriate training
If composition is unknown (e.g. a byproduct) employer will assume it is hazardous
If produced for outside user, employer must comply with HCS – SDS and labeling requirements

40. Differences from HCS SDS requirements Chemical inventory requirement
Lab Standard supersedes other regs
Annual review of CHP
Medical evaluations
Chemical Hygiene Officer
Monitoring requirements

41. Similarities to HCS Same objective Same definitions Written program
Training and information requirements

42. Questions?