Prepared by Sotaris LLP May 16, 2014

Prepared by Sotaris LLP May 16, 2014
Hazard Communication Presented to the Lake County Safety Council May 16, 2014

Today’s Presenter Darryl J. Schumacher Partner; Sotaris LLP
/ Cell 24 Years Experience in Workplace Safety Specializations Lockout/Tagout Electrical Safety / Arc Flash (NFPA70E) Hazard Communication Emergency Preparedness Planning Fall Protection

Sotaris Clients

Prepared by Sotaris LLP
Today’s Objectives Review Hazard Communication Standard (HCS) Requirements Discuss how the HCS will be impacted with the adoption of the Globally Harmonized System (GHS) Cover what you need to do to make your HAZCOM program compliant with the new GHS requirements Review new Label Elements, Hazard Statements & Pictogram and the new SDS format Target Audience: Everybody Course Description:OSHA’s Hazard Communication Standard (HCS) is currently in a transitional period as changes take effect due to the adoption of the Globally Harmonized System (GHS). This is an ideal time for employers to re-evaluate where their programs stand and make enhancements. This workshop will discuss HCS/GHS requirements and implementation strategies.

Concept of regulation Employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working. They also need to know what protective measures are available to prevent adverse effects from occurring.

Compliance The Hazcom Standard continues to be one of the most cited OSHA standard No Program or Inventory Missing Labels Missing SDS Lack of Training

HAZCOM Purpose “…ensure that employers and employees know about work 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 Training MSDS/SDS A significant portion of the standard pertains only to chemical manufactures, importers, and distributors Requires chemical producers to determine the hazards of their products, and prepare labels and safety data sheets Requires all employers with hazardous chemicals in their workplaces to have a written hazard communication program, labels on containers, safety data sheets, and worker training

HAZCOM Purpose (Cont.) Requires chemical producers to determine the hazards of their products, and prepare labels and safety data sheets Container Labeling Material Safety Data Sheet (SDS) Analysis A significant portion of the standard pertains only to chemical manufactures, importers, and distributors Requires chemical producers to determine the hazards of their products, and prepare labels and safety data sheets Requires all employers with hazardous chemicals in their workplaces to have a written hazard communication program, labels on containers, safety data sheets, and worker training Label

Labeling Exemptions Other federal agencies control labeling requirements for the following substances: Pesticides Chemicals covered under the Toxic Substance Control Act Foods or food additives Distilled spirits, tobacco Consumer products Hazardous wastes The other requirements of the HCS still apply to any of these hazardous products if they are present in the workplace and used as part of an employee’s job duties at an occupational level of exposure with a frequency and duration of exposure that is greater than that of a consumer.

Consumer Products Exemption
Prepared by Sotaris LLP Consumer Products Exemption Any consumer product as defined in the Consumer Product Safety Act where: Used in the workplace for the purpose intended Exposure within the range that could reasonably be experienced by consumers when used for intended purpose

Documenting your Program
Prepared by Sotaris LLP Documenting your Program The success of your program relies upon concisely documenting your company’s policies and protocols for dealing with hazardous chemicals in your workplace. The program or policy you create should be developed, implemented, and maintained at each physical workplace.

Employer Requirement: Written Program
Prepared by Sotaris LLP Employer Requirement: Written Program Must cover at least: Purpose and Scope of the Program List of known hazardous chemicals present and a SDS for each Labels and other forms of warnings consistent with the SDS Methods used to inform employees of hazards of non-routine tasks and the associated risks for those tasks Storage and transportation methods of hazardous chemicals and materials Hazards of chemicals in unlabeled pipes Employee Information and Training Where and how employees must travel between workplaces and work shift changes when dealing with hazardous chemicals and materials Employee Availability to Information and Training • Purpose and scope of the program • A list of known hazardous chemicals in the workplace to be listed in the format of Safety Data Sheets (SDS) • Labels that coincide with correct and current information in the SDS • Useful training and information for employees to understand elements of any revisions to the Hazard Communication standards, including new GHS labels and SDS’s • Methods for updating, evaluating, and conveying information about chemical hazards • Methods to accomplish non-routine tasks surrounding hazardous chemicals and the associated risks involved in executing those tasks (i.e. cleaning reactor vessels) • Storage and transportation methods of hazardous chemicals and materials • Where and how employees must travel between workplaces and work shift changes when dealing with hazardous chemicals and materials

Inventory Hazardous Chemicals
Prepared by Sotaris LLP Inventory Hazardous Chemicals All of the hazardous chemicals in your facility will need to be matched with properly formatted Safety Data Sheets SDS’s. Management system should also include the following details: • Location tracking • Container tracking and reconciliation reporting • Unit of measure conversions and calculations • Material approval routings • Managing restricted and banned chemicals • Notifications of exceeded thresholds To comply with OSHA’s Hazard Communication Standard, you need to first understand the range of chemicals that you have on-site at your organization. All of the hazardous chemicals in your facility will need to be matched with complete,

Safety Data Sheets (SDS)
Prepared by Sotaris LLP Safety Data Sheets (SDS) Your Employees need to have easy access to SDS at all times. Program should include a full reference section of hazardous chemicals on-site. Detail how individuals are to access and manage/maintain the system, Identify Roles and Responsibilities If necessary, provide training on electronic systems. If necessary, establish protocols for when SDSs are not available. To comply with OSHA’s Hazard Communication Standard, you need to first understand the range of chemicals that you have on-site at your organization. All of the hazardous chemicals in your facility will need to be matched with complete,

Labeling Effective Labeling protocols effectively communicate critical hazard information to your employees With the advent of GHS, specifications have been established that include the product name, hazardous ingredients, applicable physical and health hazard statements, a “Danger” or “Warning” signal word and pictogram(s), along with supplemental and contact information. All of the chemicals in your organization’s facility that are stored in containers and tanks also need to be properly labeled; Most often, when utilizing secondary containers, labeling will be necessary. Make sure your program specifies your program’s requirements. Use highly visible permanent labels to clearly communicate the chemical hazards to your employees (and customers). Your finished products must consistently be labeled with the proper hazard communication information. If it’s harmonized with the GHS, this will include the product name, hazardous ingredients, applicable physical and health hazard statements, a “Danger” or “Warning” signal word and pictogram(s), along with supplemental and contact information. All of the chemicals in your organization’s facility that are stored in containers and tanks also need to be properly labeled according to the HazCom system in effect. Chemicals are often removed from their primary containers and placed into secondary containers for use in the workplace; in such cases, the secondary containers must also be properly labeled. All pipes that carry hazardous chemicals should ideally have pipe markers at fixed distances along the route of the pipes that can be seen by everyone who encounters them. FIVE STEPS TO

Labeling (continued) The focus for labeling chemicals should be to ensure that all employees who may come in contact with chemicals can quickly recognize what chemicals they are handling the associated hazards/risks. In order to have a successful program, you must assign responsibility for both the initial and ongoing activities that have to be undertaken to comply with the rule. In some cases, these activities may be part of current job assignments. For example, Site Supervisors are frequently responsible for on-the-job training sessions. Early identification of the responsible employees and their involvement in developing your action plan will result in a more effective program design. Involving affected employees also will enhance the evaluation of the effectiveness of your program.

Labeling Overhead Pipes
Prepared by Sotaris LLP Labeling Overhead Pipes If your workplace has pipes that contain hazardous substances or that are insulated with asbestos- containing material, you must either place warning labels on the pipes to identify the hazards or use other methods, such as process sheets or written operating procedures, to warn employees Alternatives to GHS Labeling As an alternative to labeling all individual process containers, you can: Substitute various types of standard operating procedures, process sheets, batch tickets, blend tickets, and similar written materials for container labels on stationary process equipment if they contain the same information as the labels, and the written materials are readily accessible to employees in the work area throughout each work shift. Post signs or placards that convey the hazard information if there are a number of stationary containers within a work area that have similar contents and hazards. Use alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS). But remember, any alternative labeling method must be consistent with the GHS label system. All information supplied on the alternative labels must be consistent with the GHS label system. There must be no conflicting hazard statement and pictogram. - See more at:

Labeling; OSHA Looks for:
Prepared by Sotaris LLP Labeling; OSHA Looks for: Designation of person(s) responsible for ensuring labeling of in-plant containers; Designation of person(s) responsible for ensuring labeling of any shipped container; Description of labeling system(s) used; Description of written alternatives to labeling of in- plant containers (if used); and, Procedures to review and update label information when necessary. .

Training Regular Training and Program Monitoring is a key to the success of your Hazcom Program Make sure all of your employees know how to read and interpret the hazardous chemical labels and SDS’s. They should also know where the SDS’s are stored and how they can access them.

Employee Information Employers must inform employees of: Training requirements of this section Operations in their work area where hazardous chemicals are present; Location and availability of the written hazard communication program

Multi-Employer Workplaces
Prepared by Sotaris LLP Multi-Employer Workplaces When other employers have employees onsite that may be exposed, program must include: Methods to provide contractor employees with on- site access to MSDS/SDS Methods used to inform other employers of precautionary measures for normal and emergency situations The employer’s chemical labeling system

Program; OSHA Looks for:
Prepared by Sotaris LLP Program; OSHA Looks for: Does a list of the hazardous chemicals exist in each work area or at a central location? Are methods the employer will use to inform employees of the hazards of non-routine tasks outlined? Are employees informed of the hazards associated with chemicals contained in unlabeled pipes in their work areas? On multi-employer worksites, has the employer provided other employers with information about labeling systems and precautionary measures where the other employers have employees exposed to the initial employer's chemicals? Is the written program made available to employees and their designated representatives?.

What is the GHS? …an international approach to hazard communication, providing agreed criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets It is a set of guidelines for ensuring the safe production, transport, handling, use and disposal of hazardous materials

Why Adopt the GHS The goal is to reduce chemical source illnesses and injuries Acute illnesses and injuries from chemicals have decreased 42% since the Hazcom Standard was implemented in 1983 Unfortunately, there is still a critical need for effective information to protect exposed workers from chemicals; particularly from chronic effects OSHA estimates that over 43 million workers are covered by the standard and the GHS modification will prevent an estimated 500 injuries and 43 fatalities annually. The GHS was developed by the United Nations, as a way to bring into agreement the chemical regulations and standards of different countries. In short, it is an international attempt to get everyone on the same page. The hope is that every country will incorporate the tenets of the GHS into their own chemical management systems with the goal of making the international sale and transportation of hazardous chemicals easier, as well as, making workplace conditions safer for all employees exposed to chemical hazards. Employers who do not produce or import chemicals need only focus on those parts of this rule that deal with establishing a workplace program and communicating information to their workers.

GHS Enhancements Increased worker comprehension of hazards, specifically where there are literacy/language issues Reduced confusion and more effective training Quicker access to critical information

GHS Governing Authorities (U.S.)
Prepared by Sotaris LLP GHS Governing Authorities (U.S.) Occupational Safety & Health Administration (OSHA) Environmental Protection Agency (EPA) Department of Transportation (DOT) Consumer Product Safety Commission (CPSC) OSHA served as the lead U.S. agency on the classification of chemicals and hazard communication and adoption affects over 43 million workers in over 5 million workplaces. The DOT was actually the first agency to implement GHS and OSHA’s adoption brings the regulations between the agencies into greater harmony. The EPA is expected to follow closely on the heels of OSHA’s adoption with revisions to its own standards to bring them into alignment with GHS.

OSHA - Timeline

GHS changes to Hazard Communication
Prepared by Sotaris LLP GHS changes to Hazard Communication The U.S. officially adopted the GHS on March 26, OSHA’s adoption is actually a revision of the Hazard Communication Standard to align with the GHS. OSHA calls this revision, HazCom 2012 Major changes to the Hazard Communication Standard: Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures. Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category. Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information. Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

GHS changes to Hazard Communication
Prepared by Sotaris LLP GHS changes to Hazard Communication Hazard Classification Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures Labels Chemical manufacturers and importers must provide a newly formatted label on their products Safety Data Sheets New format requires 16 specific sections Information and Training Training by December 1, 2011 Major changes to the Hazard Communication Standard: Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures. Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category. Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information. Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

GHS Classification Process
Prepared by Sotaris LLP GHS Classification Process Chemical manufacturers and importers shall evaluate chemicals produced in their workplaces or imported by them to classify the chemicals in accordance with this section. For each chemical, the chemical manufacturer or importer shall determine the hazard classes, and where appropriate, the category of each class that apply to the chemical being classified. Employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer or importer for the chemical to satisfy this requirement. Major changes to the Hazard Communication Standard: Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures. Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category. Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information. Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

GHS Classification For classification, the GHS applies to pure substances and their dilute solutions and to mixtures. It does not apply to “articles” as defined by OSHA Substances means chemical elements and their compounds in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product. Mixtures means a mixture or solution composed of two or more substances in which they do not react Alloy means a metallic material, homogeneous on a macroscopic scale, consisting of two or more elements so combined that they cannot be readily separated by mechanical means. Alloys are considered to be mixtures for the purposes of classification under the GHS. Major changes to the Hazard Communication Standard: Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures. Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category. Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information. Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

GHS Classification For classification, the GHS applies to pure substances and their dilute solutions and to mixtures. It does not apply to “articles” as defined by OSHA “Article” means a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical (as determined under paragraph (d) of this section), and does not pose a physical hazard or health risk to employees Major changes to the Hazard Communication Standard: Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures. Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category. Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information. Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

Employer Responsibility
Prepared by Sotaris LLP Employer Responsibility Located in Various Locations New hire, annual , job specific Available at all facilities List of Hazardous Chemicals SDS for Chemicals Written Program Provide Training Provide PPE

Health Hazards Acute Toxicity Skin Corrosion/Irritation Serious Eye Damage/Irritation

Health Hazards Respiratory or Skin Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Target Organ Systemic Toxicity – Single and Repeated Dose

Physical Hazards Explosives Flammability – gases, aerosols, liquids, solids Oxidizers – liquid, solid, gases Self-Reactive Pyrophoric – liquids, solids

Physical Hazards Self-Heating Organic Peroxides Corrosive to Metals Gases Under Pressure Water-Activated Flammable Gases

Environmental Hazards
Prepared by Sotaris LLP Environmental Hazards Hazardous to the Aquatic Environment

Current Labeling Systems
Prepared by Sotaris LLP Current Labeling Systems NFPA Degree Scale 4 – Extreme 3 – Serious 2 – Moderate 1 – Slight 0 - Minimal One issue of concern is that under GHS, numbers are used to rank hazards based upon their seriousness. Those rankings occur under what are called Hazard Categories, with lower numbers indicating greater hazards. The NFPA and HMIS on the other hand also use numbers to indicate hazard severity – only in their systems, the higher the number the more serious the hazard. Credit: MSDS Online

Current Labeling Systems
Prepared by Sotaris LLP Current Labeling Systems HMIS / HMCIS Degree Scale 4 – Extreme 3 – Serious 2 – Moderate 1 – Slight 0 - Minimal National Fire Protection Association Hazardous Materials Information System

GHS Label Elements Hazard Statement and Precautionary Statements and Pictograms: Measures to minimize or prevent adverse effects. Product Identifier (ingredient disclosure): Name or number used for a hazardous product on a label or in the SDS. Supplier identification: The name, address and telephone number should be provided on the label. Supplemental information: Non-harmonized information. National Fire Protection Association Hazardous Materials Information System

GHS Label Prepared by Sotaris LLP Note that the actual layout of the label is not specified provided that each element is addressed OSHA requires name, signal word, haz state, pictograms Harmonized signal word: 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. GHS 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). 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. Precautionary statement: a phrase that describes recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous chemical; or improper storage or handling of a hazardous chemical. Supplier identification: The name, address and telephone number of the manufacturer or supplier of the substance or mixture should be provided on the label. The Working Group identified about 35 different types of information that are currently required on labels by different systems. To harmonize, key information elements needed to be identified. Additional harmonization may occur on other elements in time, in particular for precautionary statements.

GHS Label Prepared by Sotaris LLP OSHA requires name, signal word, haz state, pictograms Harmonized signal word: 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. GHS 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). 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. Precautionary statement: a phrase that describes recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous chemical; or improper storage or handling of a hazardous chemical. Supplier identification: The name, address and telephone number of the manufacturer or supplier of the substance or mixture should be provided on the label. The Working Group identified about 35 different types of information that are currently required on labels by different systems. To harmonize, key information elements needed to be identified. Additional harmonization may occur on other elements in time, in particular for precautionary statements.

GHS Label Prepared by Sotaris LLP For hazardous products being transported, outer containers have required label elements, product identifier and hazard symbols. Transportation requirements are in addition to workplace or end use label requirements. DOT 1: Explosives DOT 2: Gases DOT 3: Flammable Liquids DOT 4: Flammable Solids DOT 5: Oxidizing Substances DOT 6: Poisons DOT 7: Radioactive Materials DOT 8: Corrosive Materials DOT 9: Miscellaneous Hazardous Materials

GHS Label Prepared by Sotaris LLP Several arrangements for GHS labels are also provided in Annex 7 of the Purple Book. Figure 4.13 shows an arrangement for a combination packaging with an outer shipping box and inner bottles. The shipping box has a transportation pictogram. The inner bottles have a GHS label with a GHS pictogram. OSHA requires name, signal word, haz state, pictograms Harmonized signal word: 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. GHS 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). 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. Precautionary statement: a phrase that describes recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous chemical; or improper storage or handling of a hazardous chemical. Supplier identification: The name, address and telephone number of the manufacturer or supplier of the substance or mixture should be provided on the label. The Working Group identified about 35 different types of information that are currently required on labels by different systems. To harmonize, key information elements needed to be identified. Additional harmonization may occur on other elements in time, in particular for precautionary statements.

GHS Label Prepared by Sotaris LLP For a container such as a 55 gallon drum, the transport required markings and pictograms may be combined with the GHS label elements or presented separately. In Figure 4.14 a label arrangement for a single packaging such as a 55 gallon drum is shown. Pictograms and markings required by the transport regulations as well as GHS label and non-duplicative GHS pictogram are shown on the drum. OSHA requires name, signal word, haz state, pictograms Harmonized signal word: 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. GHS 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). 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. Precautionary statement: a phrase that describes recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous chemical; or improper storage or handling of a hazardous chemical. Supplier identification: The name, address and telephone number of the manufacturer or supplier of the substance or mixture should be provided on the label. The Working Group identified about 35 different types of information that are currently required on labels by different systems. To harmonize, key information elements needed to be identified. Additional harmonization may occur on other elements in time, in particular for precautionary statements.

GHS Label Prepared by Sotaris LLP A label merging the transportation requirements and the GHS requirements into one label for the fictional product "ToxiFlam" is shown in Figure This combined type label could also be used on a 55 gallon drum. OSHA requires name, signal word, haz state, pictograms Harmonized signal word: 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. GHS 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). 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. Precautionary statement: a phrase that describes recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous chemical; or improper storage or handling of a hazardous chemical. Supplier identification: The name, address and telephone number of the manufacturer or supplier of the substance or mixture should be provided on the label. The Working Group identified about 35 different types of information that are currently required on labels by different systems. To harmonize, key information elements needed to be identified. Additional harmonization may occur on other elements in time, in particular for precautionary statements.

Signal Words Used to emphasize hazard and discriminate between levels of hazard. "Signal word" means a 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 in this section are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for the less severe.

Hazard Statements A single harmonized hazard statement for each level of hazard within each hazard class Example: Flammable liquids Category 1: Extremely flammable liquid and vapor Category 2: Highly flammable liquid and vapor Category 3: Flammable liquid and vapor Category 4: Combustible liquid Note that unlike NFPA and HMIS Labels, GHS Labels will not include numbers. Statement that describes the nature of the hazard(s) of a chemical

Precautionary Statement
Prepared by Sotaris LLP Precautionary Statement Precautionary information supplements the hazard information by briefly providing measures to be taken to minimize or prevent adverse effects from physical, health or environmental hazards. First aid is included in precautionary information. Annex 3 of the GHS Purple Book includes precautionary statements and pictograms that can be used on labels. GHS label needs to appropriately address: Prevention Response Storage Disposal Recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous chemical The GHS document includes examples of precautionary statements which can be used. The intent is to harmonize precautionary statements in the future. Precautionary statement – 4 types… Prevention, Response, Storage, Disposal

Product Identifier (ingredient disclosure)
Prepared by Sotaris LLP Product Identifier (ingredient disclosure) A product identifier should be used on a GHS label and it should match the product identifier used on the SDS. Where a substance or mixture is covered by the UN Model Regulations on the Transport of Dangerous Goods, the UN proper shipping name should also be used on the package. Recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous chemical The GHS document includes examples of precautionary statements which can be used. The intent is to harmonize precautionary statements in the future. Precautionary statement – 4 types… Prevention, Response, Storage, Disposal

Supplier Information GHS label need to include all pertinent contact information associated with the manufacturer of the chemical. Company Name Address Phone Website The name, address and telephone number of the manufacturer

Workplace Warnings Old Format New Format The name, address and telephone number of the manufacturer

GHS Pictograms “Pictogram” means a composition that may include 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. Eight pictograms are designated under this standard for application to a hazard category The name, address and telephone number of the manufacturer

Health Hazard This pictogram is put on a chemical label when a substance presents these health hazards: Carcinogen--may cause cancer Respiratory sensitizer--may cause respiratory irritation Reproductive toxicity--may damage fertility or the unborn child Target organ toxicity--may cause damage to bodily organs Mutagenicity--may cause genetic defects Aspiration toxicity--may be fatal if swallowed and it enters the airways

Flame Flammables - gases, aerosols, liquids, or solids that will burn or ignite under certain conditions, Self-Reactives-heating alone, without air, may cause fire or explosion, Pyrophorics--in small amounts, may ignite within 5 minutes after contact with air, Self-Heating--which may catch fire only in large amounts and after long periods of time when exposed to air, Emitters of flammable gas, and Organic peroxides--which, when heated, may cause fire or explosion; may be sensitive to impact or friction; and may react dangerously with other chemicals.

Flame over Circle This symbol on a chemical label means that the substance is an oxidizer. Oxidizers may cause a fire by increasing the concentration of oxygen in the air.

Exclamation Mark It is used on a chemical label for substances that represent the following hazards: Irritant--irritates the skin or eyes; Skin sensitizer--which is an allergic response following skin contact; Acute toxicity--which may be fatal or cause organ damage from a single short-term exposure; Narcotic effects like drowsiness, lack of coordination, and dizziness; and Respiratory tract irritation.

Gas Cylinder This pictogram on a chemical label means that the substance is a compressed, liquefied, or dissolved gas under pressure at 29 pounds per square inch or more.

Exploding Bomb The exploding bomb pictogram appears on the chemical labels of substances that are: Explosives—which is a solid or liquid chemical capable of a chemical reaction that causes damage to the surroundings, Self-Reactive—heating may cause fire or explosion without the need for air, or Organic peroxides —again, heating may cause fire or explosion.

Corrosion This pictogram on a chemical label means that the substance causes skin burns, eye damage, or destroys metals.

Environment This non-mandatory pictogram means the hazard the chemical presents is aquatic toxicity.

Skull and Crossbones Substances with a hazard of acute toxicity will have this symbol on their chemical label. Acute toxicity means that exposure to a single dose of the chemical may be toxic or fatal if inhaled or swallowed, or if it comes into contact with the skin.

SDS Format: 16 Headings The Safety Data Sheet (SDS) provides comprehensive information for use in workplace chemical management. Employers and workers use the SDS as sources of information about hazards and to obtain advice on safety precautions. The SDS is product related and, usually, is not able to provide information that is specific for any given workplace where the product may be used. The revised Purple Book contains guidance on developing a GHS SDS (Annex 4). The SDS should provide comprehensive information about a chemical substance or mixture. Primary Use: The Workplace Employers and workers use the SDS as a source of information about hazards and to obtain advice on safety precautions. 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 Exposure control/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

Section 1: Identification
Prepared by Sotaris LLP Section 1: Identification Product identifier Name, address, phone number of the manufacturer, and emergency phone number. Recommended use; restrictions on use This section identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier. The required information consists of: • Product identifier used on the label and any other common names or synonyms by which the substance is known. • Name, address, phone number of the manufacturer, importer, or other responsible party, and emergency phone number. • Recommended use of the chemical (e.g., a brief description of what it actually does, such as flame retardant) and any restrictions on use (including recommendations given by the supplier).

Section 2: Hazard(s) Identification
Prepared by Sotaris LLP Section 2: Hazard(s) Identification Hazard classification Signal word Hazard statement(s) Pictograms Precautionary statement(s) Other hazards Percentage of mixture with unknown acute toxicity This section identifies the hazards of the chemical presented on the SDS and the appropriate warning information associated with those hazards. The required information consists of: • The hazard classification of the chemical (e.g., flammable liquid, category1). • Signal word. • Hazard statement(s). • Pictograms (the pictograms or hazard symbols may be presented as graphical reproductions of the symbols in black and white or be a description of the name of the symbol (e.g., skull and crossbones, flame). • Precautionary statement(s). • Description of any hazards not otherwise classified. • For a mixture that contains an ingredient(s) with unknown toxicity, a statement describing how much (percentage) of the mixture consists of ingredient(s) with unknown acute toxicity. Please note that this is a total percentage of the mixture and not tied to the individual ingredient(s).

Section 2: Hazard ID (cont.)
Prepared by Sotaris LLP Section 2: Hazard ID (cont.)

Section 3: Composition/Information on Ingredients
Prepared by Sotaris LLP Section 3: Composition/Information on Ingredients Chemical name Common name and synonyms CAS # (Chemical Abstracts Service) Other unique identifiers This section identifies the ingredient(s) contained in the product indicated on the SDS, including impurities and stabilizing additives. This section includes information on substances, mixtures, and all chemicals where a trade secret is claimed. The required information consists of: Substances • Chemical name. • Common name and synonyms. • Chemical Abstracts Service (CAS) number and other unique identifiers. • Impurities and stabilizing additives, which are themselves classified and which contribute to the classification of the chemical. Mixtures • Same information required for substances. • The chemical name and concentration (i.e., exact percentage) of all ingredients which are classified as health hazards and are: ° Present above their cut-off/concentration limits or ° Present a health risk below the cut-off/concentration limits. • The concentration (exact percentages) of each ingredient must be specified except concentration ranges may be used in the following situations: ° A trade secret claim is made, ° There is batch-to-batch variation, or ° The SDS is used for a group of substantially similar mixtures. Chemicals where a trade secret is claimed • A statement that the specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a trade secret is required.

Section 4: First-Aid Measures
Prepared by Sotaris LLP Section 4: First-Aid Measures First-aid instructions Description of symptoms Required treatment This section describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical. The required information consists of: • Necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact, and ingestion). • Description of the most important symptoms or effects, and any symptoms that are acute or delayed. • Recommendations for immediate medical care and special treatment needed, when necessary.

Section 5: Fire-Fighting Measures
Prepared by Sotaris LLP Section 5: Fire-Fighting Measures Lists suitable extinguishing techniques and equipment Chemical hazards from fire This section provides recommendations for fighting a fire caused by the chemical. The required information consists of: • Recommendations of suitable extinguishing equipment, and information about extinguishing equipment that is not appropriate for a particular situation. • Advice on specific hazards that develop from the chemical during the fire, such as any hazardous combustion products created when the chemical burns. • Recommendations on special protective equipment or precautions for firefighters.

Section 6: Accidental Release Measures
Prepared by Sotaris LLP Section 6: Accidental Release Measures Use of personal precautions and protective equipment Emergency procedures Methods and materials used for containment and cleanup This section provides recommendations on the appropriate response to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people, properties, or the environment. It may also include recommendations distinguishing between responses for large and small spills where the spill volume has a significant impact on the hazard. The required information may consist of recommendations for: • Use of personal precautions (such as removal of ignition sources or providing sufficient ventilation) and protective equipment to prevent the contamination of skin, eyes, and clothing. • Emergency procedures, including instructions for evacuations, consulting experts when needed, and appropriate protective clothing. • Methods and materials used for containment (e.g., covering the drains and capping procedures). • Cleanup procedures (e.g., appropriate techniques for neutralization, decontamination, cleaning or vacuuming; adsorbent materials; and/or equipment required for containment/clean up).

Section 7: Handling and Storage
Prepared by Sotaris LLP Section 7: Handling and Storage Precautions for safe handling Handling of incompatible chemicals Minimizing the release into the environment Providing general hygiene practices. Conditions for safe storage, including any incompatibilities. This section provides guidance on the safe handling practices and conditions for safe storage of chemicals. The required information consists of: • Precautions for safe handling, including recommendations for handling incompatible chemicals, minimizing the release of the chemical into the environment, and providing advice on general hygiene practices (e.g., eating, drinking, and smoking in work areas is prohibited). • Recommendations on the conditions for safe storage, including any incompatibilities. Provide advice on specific storage requirements (e.g., ventilation requirements).

Section 8: Exposure Controls/Personal Protection
Prepared by Sotaris LLP Section 8: Exposure Controls/Personal Protection OSHA (PELs) ACGIH Threshold Limit Values (TLVs) Appropriate engineering controls Personal protective equipment This section indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure. The required information consists of: • OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available. • Appropriate engineering controls (e.g., use local exhaust ventilation, or use only in an enclosed system). • Recommendations for personal protective measures to prevent illness or injury from exposure to chemicals, such as personal protective equipment (PPE) (e.g., appropriate types of eye, face, skin or respiratory protection needed based on hazards and potential exposure). • Any special requirements for PPE, protective clothing or respirators (e.g., type of glove material, such as PVC or nitrile rubber gloves; and breakthrough time of the glove material)

Section 8: Exposure Controls/Personal Protection (cont.)
Prepared by Sotaris LLP Section 8: Exposure Controls/Personal Protection (cont.) This section indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure. The required information consists of: • OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available. • Appropriate engineering controls (e.g., use local exhaust ventilation, or use only in an enclosed system). • Recommendations for personal protective measures to prevent illness or injury from exposure to chemicals, such as personal protective equipment (PPE) (e.g., appropriate types of eye, face, skin or respiratory protection needed based on hazards and potential exposure). • Any special requirements for PPE, protective clothing or respirators (e.g., type of glove material, such as PVC or nitrile rubber gloves; and breakthrough time of the glove material)

Section 9: Physical and Chemical Properties
Prepared by Sotaris LLP Section 9: Physical and Chemical Properties Upper/lower flammability or explosive limits Vapor pressure Vapor density Relative density Solubility(ies) Auto-ignition temperature Decomposition temperature Viscosity Appearance Odor Odor threshold pH Relative density; Melting point/freezing point Initial boiling point and boiling range Flash point Evaporation rate Flammability (solid, gas) This section identifies physical and chemical properties associated with the substance or mixture. The minimum required information consists of: The SDS may not contain every item on the above list because information may not be relevant or is not available. When this occurs, a notation to that effect must be made for that chemical property. Manufacturers may also add other relevant properties, such as the dust deflagration index (Kst) for combustible dust, used to evaluate a dust’s explosive potential.

Section 9: Physical and Chemical Properties (Cont.)
Prepared by Sotaris LLP Section 9: Physical and Chemical Properties (Cont.)

Section 10: Stability and Reactivity
Prepared by Sotaris LLP Section 10: Stability and Reactivity Reactivity Description of the specific test data Chemical Stability Stable or unstable under normal ambient temperature and conditions while in storage and being handled. Description of any stabilizers Indication of any safety issues Other Indication of the possibility of hazardous reactions Conditions to avoid List of all classes of incompatible materials List of any known or anticipated hazardous decomposition products This section describes the reactivity hazards of the chemical and the chemical stability information. This section is broken into three parts: reactivity, chemical stability, and other. The required information consists of: Reactivity • Description of the specific test data for the chemical(s). This data can be for a class or family of the chemical if such data adequately represent the anticipated hazard of the chemical(s), where available. Chemical stability • Indication of whether the chemical is stable or unstable under normal ambient temperature and conditions while in storage and being handled. • Description of any stabilizers that may be needed to maintain chemical stability. • Indication of any safety issues that may arise should the product change in physical appearance. Other • Indication of the possibility of hazardous reactions, including a statement whether the chemical will react or polymerize, which could release excess pressure or heat, or create other hazardous conditions. Also, a description of the conditions under which hazardous reactions may occur. • List of all conditions that should be avoided (e.g., static discharge, shock, vibrations, or environmental conditions that may lead to hazardous conditions). • List of all classes of incompatible materials (e.g., classes of chemicals or specific substances) with which the chemical could react to produce a hazardous situation. • List of any known or anticipated hazardous decomposition products that could be produced because of use, storage, or heating. (Hazardous combustion products should also be included in Section 5 (Fire-Fighting Measures) of the SDS.)

Section 11: Toxicological Information
Prepared by Sotaris LLP Section 11: Toxicological Information Routes of exposure Description of the symptoms Acute and Chronic effects Numerical measures of toxicity This section identifies toxicological and health effects information or indicates that such data are not available. The required information consists of: • Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact). The SDS should indicate if the information is unknown. • Description of the delayed, immediate, or chronic effects from short- and long-term exposure. • The numerical measures of toxicity (e.g., acute toxicity estimates such as the LD50 (median lethal dose)) - the estimated amount [of a substance] expected to kill 50% of test animals in a single dose. • Description of the symptoms. This description includes the symptoms associated with exposure to the chemical including symptoms from the lowest to the most severe exposure. • Indication of whether the chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions) or found to be a potential carcinogen by OSHA.

Section 12: Ecological Information (non-mandatory)
Prepared by Sotaris LLP Section 12: Ecological Information (non-mandatory) Data from toxicity tests Whether there is a potential for the chemical to persist and degrade in the environment Results of tests of bioaccumulation potential The potential for a substance to move from the soil to the groundwater Other adverse effects This section provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment. The information may include: • Data from toxicity tests performed on aquatic and/or terrestrial organisms, where available (e.g., acute or chronic aquatic toxicity data for fish, algae, crustaceans, and other plants; toxicity data on birds, bees, plants). • Whether there is a potential for the chemical to persist and degrade in the environment either through biodegradation or other processes, such as oxidation or hydrolysis. • Results of tests of bioaccumulation potential, making reference to the octanol-water partition coefficient (Kow) and the bioconcentration factor (BCF), where available. • The potential for a substance to move from the soil to the groundwater (indicate results from adsorption studies or leaching studies). • Other adverse effects (e.g., environmental fate, ozone layer depletion potential, photochemical ozone creation potential, endocrine disrupting potential, and/or global warming potential).

Section 13: Disposal Considerations (non-mandatory)
Prepared by Sotaris LLP Section 13: Disposal Considerations (non-mandatory) Proper disposal practices, recycling or reclamation and safe handling practices. Description of appropriate disposal containers Recommendations of appropriate disposal methods This section provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container, and safe handling practices. To minimize exposure, this section should also refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS. The information may include: • Description of appropriate disposal containers to use. • Recommendations of appropriate disposal methods to employ. • Description of the physical and chemical properties that may affect disposal activities. • Language discouraging sewage disposal. • Any special precautions for landfills or incineration activities.

Section 14: Transport Information (non-mandatory)
Prepared by Sotaris LLP Section 14: Transport Information (non-mandatory) Classification information for shipping and transporting of hazardous chemical UN number/shipping name Transport hazard class(es) Packing group number Guidance on transport in bulk Any special precautions This section provides guidance on classification information for shipping and transporting of hazardous chemical(s) by road, air, rail, or sea. The information may include: • UN number (i.e., four-figure identification number of the substance)2. • UN proper shipping name2. • Transport hazard class(es)2. • Packing group number, if applicable, based on the degree of hazard2. • Environmental hazards (e.g., identify if it is a marine pollutant according to the International Maritime Dangerous Goods Code (IMDG Code)). • Guidance on transport in bulk (according to Annex II of MARPOL 73/783 and the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (International Bulk Chemical Code (IBC Code)). • Any special precautions which an employee should be aware of or needs to comply with, in connection with transport or conveyance either within or outside their premises (indicate when information is not available).

Section 15: Regulatory Information (non-mandatory)
Prepared by Sotaris LLP Section 15: Regulatory Information (non-mandatory) Identifies the safety, health, and environmental regulations Any national and/or regional regulatory information of the chemical or mixtures This section identifies the safety, health, and environmental regulations specific for the product that is not indicated anywhere else on the SDS. The information may include: • Any national and/or regional regulatory information of the chemical or mixtures (including any OSHA, Department of Transportation, Environmental Protection Agency, or Consumer Product Safety Commission regulations).

Section 16: Other Information
Prepared by Sotaris LLP Section 16: Other Information Indicates when the SDS was prepared or when the last known revision was made. This section 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. You may wish to contact the supplier for an explanation of the changes. Other useful information also may be included here.

Transitioning from MSDS to SDS
Prepared by Sotaris LLP Transitioning from MSDS to SDS Carefully Plan the means by which you will be transitioning from MSDS to SDS on the plant floor: Review current Binder to determine accuracy Achieve Older Sheets (DO NOT DISCARD!) Verify that all inventoried Chemicals have MSDS/SDS If requesting new MSDS/SDS be certain that you are procuring for the exact chemical you have in your possession As part of review, evaluate PPE, Storage, Spill Plans, Training, etc. Establish a plan for interim markings for portable storage containers This section 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. You may wish to contact the supplier for an explanation of the changes. Other useful information also may be included here.

Hazcom Employer To-Do List
Prepared by Sotaris LLP Hazcom Employer To-Do List Train employees on new GHS-style label elements Train employees on new SDS format Continue to update safety data sheets when new ones become available Update written hazard communication programs if new hazards are identified Update alternative workplace labeling as necessary Provide additional employee training for newly identified physical or health hazards Make sure all container labels in the workplace are compliant

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Prepared by Sotaris LLP May 16, 2014

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Prepared by Sotaris LLP May 16, 2014

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