1. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. 65 th Annual Wilmington Regional Safety & Health School July 30 & 31, 2015 Globally Harmonized System (HazCom) Compliance Chuck Haling

2. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS: 2 Deadlines Hit in 2015 Are You Ready? Chuck Haling VP of Sales, MSDSonline

3. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Review OSHA’s HCS and UN’s GHS Discuss OSHA’s adoption of GHS and resulting HazCom changes Review deadlines and expectations Describe ways to manage the GHS transition to ensure compliance Presentation Goals

4. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. What is HCS?

5. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Hazard Communication 1910.1200 TheReg HazComStandard HazCom TheHazComReg 29 CFR 1910. 1200 RighttoKnow RTK HCS HazCom1994 HazComm

6. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. What is HCS? Hazard Communication Standard OSHA Regulation - Protects workers from hazardous chemicals Adopted in 1983 Covers 43 million U.S. workers and 5 million workplaces Covers 880,000+ chemicals and millions of safety data sheets

7. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Why Are We Reviewing HazCom Basics? A: Because a lot of the compliance questions OSHA receives about GHS, actually pertain to obligations that have been in place for decades under the pre- GHS-aligned HazCom Standard. ?

8. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Many of the ‘GHS’ compliance questions OSHA receives actually pertain to obligations that have been in place for decades under the pre-GHS-aligned HazCom Standard A:A:A:A:

9. Copyright © 2001-2014, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. From 2009 – 2014 OSHA cited over 37,000 instances of HCS violations in workplaces across the United States Ranked #2 on OSHA’s top 10 list of most frequently cited standards in 2012, 2013 & 2014 and #3 in previous years Penalties for Noncompliance Are Real Source: www.OSHA.gov

10. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Who has Responsibilities under HCS?

11. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. 3 Groups Have Responsibilities Chemical Manufacturers Evaluate and now also classify hazards of chemicals Provide Labels & MSDSs to downstream users Chemical Importers & Distributors Provide Labels & MSDSs to Employers they ship to Employers: End-Users of Chemicals Components of Compliant HazCom Program: 1.Written HazCom Plan 2.Chemical Inventory List 3.Proper Labels and Warnings 4.MSDSs and Right-to- Know Access 5.Training 213

12. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Why the Need for GHS ? OSHA seems to have things covered

13. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Hazardous chemical regulations vary by country Results in International trade barriers Extra time and $ to manage Confusion for end-users

14. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS

15. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. With GHS, Countries' hazardous chemical regulations become more aligned

16. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Common & coherent global approach To Classifying, Defining and Communicating Hazards Provides Consistency/ Harmonization to Labels and Safety Data Sheets GHS = Globally Harmonized System of Classification and Labelling of Chemicals UN 1 st edition published in 2003 Result of 1992 Rio Earth Summit OSHA chaired The Coordinating Group that developed the system

17. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS adoption of

18. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Final Rule went into effect May 2012 Based on UN's GHS Rev. 3 (2009) HCS framework remains (Bulk of Technical Info is Located in Appendices) Aims to Enhance Protections Phased-in process During transition can comply with old, new, or a combo of old and new HazCom adoption of GHS

19. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. HazCom 2012 Right-to-Understand (RTU) Standard "The standard that gave workers the right to know, now gives them the right to understand." Source: OSHA's HazCom Web page

20. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. … 2 years UN Updates GHS Every OSHA has long-term action goal to align with Rev. 6 RIN 1218-AC93: OSHA considering adopting Rev. 6 hazard categories: Desensitized explosives and Pyrophoric gases

21. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Appendix A: Health Hazard Criteria Appendix B: Physical Hazard Criteria Appendix C: Allocation of Label Elements Appendix D: Safety Data Sheets Appendix E: Definition of "Trade Secret” Appendix F: Guidance for Hazard Classification Regarding Carcinogenicity HazCom 2012 Appendices Recipe Book

22. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. FAQ1: What is my Deadline to Comply?

23. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS Alignment Timeline 1 Dec. 1, 2013 ─ EMPLOYERS Train on new label elements and SDS format 2 June 1, 2015 ─ MANUFACTURERS, DISTRIBUTORS & IMPORTERS Reclassify chemicals, and update all SDSs and labels to GHS format 3 Dec. 1, 2015 ─ DISTRIBUTORS Begin sending only GHS-labeled products and safety data sheets 4 June 1, 2016 ─ EMPLOYERS Update alternative workplace labeling and HazCom Program as needed, and provide addtl. employee training for newly identified physical or health hazards ANYTIME during Transition EMPLOYERS, MANUFACTURERS and DISTRIBUTORS Comply with either HazCom 1994, or HazCom 2012, or both Also applies to EMPLOYERS who choose to perform the classifica- tions instead of relying on Mfr/Distr/ Imptr Ongoing Obligation

24. Copyright © 2001-2014, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Do your employees know what this is? Used for indicating Gases Under Pressure Pictogram Gas Cylinder Why Employer Training is Important…

25. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS Compliance Waterfall Effect for June 1, 2015

26. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Chemical Blenders...

27. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Deadline Did Not Change On Oct. 31, 2014 OSHA responded to ACA’s petition for relief from the June 1, 2015 deadline, saying its June 1 deadline would not change However, OSHA is willing to use “enforcement discretion” to determine if a good faith effort has been made to comply Image Source: MSDSonline EHS BlogMSDSonline EHS Blog

28. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Image Source: OSHA WebsiteOSHA Website Applies to June 1, 2015 Effective Date OSHA Enforcement Memo issued Feb. 9, 2015 for Chemical Manufacturers, Distributors & Importers of chemical mixtures “Reasonable Diligence” & “Good Faith Effort” criteria Time period to develop HCS- 2012 compliant SDSs & Labels SDSs: 6 months from receiving info from supplier Labels: 6 months after SDS is created Distributors can ship chemicals labeled with HCS-1994 compliant labels until Dec. 1, 2017 If criteria in memo apply

29. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Image Source: OSHA WebsiteOSHA Website June 1 Interim OSHA Enforcement Guidance issued May 29, 2015 NEW: Stock packaged pre-June 1 can be shipped with its older labels post-June 1 … BUT shipments must include HCS 2012-compliant Labels and SDSs for each and every individual container shipped unless able to demonstrate reasonable diligence and good faith as discussed in the policy

30. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. FAQ2: What are the Biggest Changes to HazCom as a Result of GHS Adoption?

31. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. At a High Level, Much is the Same

32. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. 1)Hazard Classification Criteria Health Hazards Physical Hazards Mixtures 2) Hazard ‘Communication’ Labels Safety Data Sheets Training Two Most Prevalent Changes

33. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. “Hazardous Chemical” means any chemical which is classified as a 1) Physical hazard; or 2) Health hazard; or 3) Simple asphyxiant; or 4) Combustible dust; or 5) Pyrophoric gas; or 6) Hazard Not Otherwise Classified (HNOC) Under New OSHA Definition… OSHA added 3 classes of chemicals that were defined in its HCS 1994, but weren’t in the UN's GHS Rev.3

34. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. The way chemicals are classified has changed New definition of hazardous chemical New concept of severity Adds layers and categories to hazard class

35. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. "Classification means to identify the relevant data regarding the hazards of a chemical; review those data to ascertain the hazards associated with the chemical; and decide whether the chemical will be classified as hazardous according to the definition of hazardous chemical...” AND to determine the "degree of hazard, where appropriate.." OSHA added this definition to HazCom

36. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Physical Explosives Flammable – Gases, Aerosols Liquids, Solids Oxidizers– liquids, solids, gases Self-Reactive Substances Self-Heating Substances Pyrophoric – liquids, solids Organic Peroxides Corrosive to Metals Gases Under Pressure Water-Activated Flammable Gases UN's GHS Hazard Classifications New to HCS with GHS adoption

37. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Health & Environmental Acute Toxicity Aspiration Toxicity Skin Corrosion/Irritation Serious Eye Damage/Eye Irritation Respiratory or Skin Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Target Organ Systemic Toxicity – Single and Repeated Dose Hazardous to the Aquatic Environment/Aquatic Toxicity Hazardous to the Ozone Layer UN’s GHS Hazard Classifications New to HCS with GHS adoption Outside OSHA’s Jurisdiction

38. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS / HazCom 2012 Classification Example of Classification Criteria with Categories

39. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. HazCom 1994 vs HazCom 2012 HCS/HazCom 1994 Gases Under Pressure Carcinogenicity GHS Alignment/ HazCom 2012 Compressed Gases Refrigerated Gases Liquefied Gases Dissolved Gases Carcinogenicity Category 1 1A = Known 1B = Probable Category 2 Suspected Note the numbering scheme: Lower the #, the more severe the hazard

40. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. FAQ3: What are the New Label Requirements?

41. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. 2 Types of Labels with 2 Different Requirements 1) Shipped Container Labels2) Workplace Container Labels

42. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. * Standardized under GHS ** Standardized under HCS 1) Product/Chemical Identifier 2) Signal Word* Danger or Warning 3) Pictograms* 4) Hazard Statements* 5) Precautionary Statements** 4 Types: Prevention/ Response/ Storage / Disposal 6) Supplier Identifier 6 Main Elements - Shipped Label Addtl. non-conflicting info is permitted

43. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. 9 GHS Pictograms Explosives Self Reactive Organic Peroxide Flammable Self Reactive Pyrophoric Self-Heating Emits Flammable Gas Organic Peroxides Oxidizers Gases Under Pressure Acute Toxicity (Fatal or toxic) Skin Corrosion/ Burns Corrosive to Metals Serious Eye Damage Carcinogenicity Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity Aspiration Toxicity Skin & Eye Irritant Dermal Sensitizer Acute Toxicity (Harmful) Narcotic Effects Respiratory Tract Irritant Harmful to Ozone Layer (Not mandatory) Aquatic Toxicity Health Hazard Gas Cylinder Exploding Bomb Flame Flame Over Circle Corrosion Environment Exclamation Mark Skull and Crossbones (Not mandatory for HazCom 2012)

44. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Labeling Small Containers “Labeling can be done with pull-out labels, fold back labels, tags or other methods. While pull- out labels, fold back labels, tags or other methods to attach the label to the shipped container may cost more than traditional glued on labels, an increase in cost is an unacceptable reason to avoid use of these labeling methods.” — OSHA Letter of Interpretation, 6/04/13

45. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Labeling Individual Containers “OSHA’s expectation is that the immediate container of the hazardous chemical is labeled.” — OSHA Letter of Interpretation, 6/04/13

46. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. 2 Types of Labels with 2 Different Requirements 1) Shipped Container Labels2) Workplace Container Labels

47. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Requirements for Shipped Labels Requirements for Workplace Labels Compliance is still performance-based Compliance is now prescriptive Workplace Labels

48. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Workplace Labeling Options Replicate Manufacturer Shipped Label 1

49. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Workplace Labeling Options Use Combination of GHS Label Elements that + Training + Other Info immediately available to employees, provides specific hazard details 2 Acetone Highly Flammable Use in well-ventilated area

50. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Workplace Labeling Options Use Homegrown System so long as employees have info on all health and physical hazards 3 Acetone Highly Flammable

51. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Workplace Labeling Options Also, continue to use NFPA or HMIS systems so long as: 1.Product Identifier is provided 2.Info is consistent with HazCom requirements 3.Employees have immediate access to specific hazard info and are fully aware of all chemical hazards (chronic and acute) Acetone Highly Flammable Use in well-ventilated area

52. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Workplace Labeling Compliance Workplace Label System Workplace Label Training Other Info in Workplace Provides employees with immediate access to all hazard information about a chemical

53. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Shipped & Workplace Labels Must not be removed or defaced Unless immediately replaced Must be legible and prominently displayed Must be in English Other languages permitted (in addition to English)

54. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. FAQ4: How are Material Safety Data Sheets Changing?

55. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. The NAME changes, but NOT THE PURPOSE =

56. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Safety Data Sheets Redefined as Safety Data Sheets (SDS) Prescribed, strictly ordered 16-section format Essentially the ANSI Standard Several Sections of Info Not Mandatory Sections 12-15 Ecological information Disposal considerations Transport information Regulatory information Outside of OSHA’s jurisdiction HCS Appendix D Details what is to be included in each section =

57. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Safety Data Sheets – Headings 1.Identification 2.Hazard(s) Identification 3.Composition/Ingredient Information 4.First-Aid Measures 5.Fire-Fighting Measures 6.Accidental Release Measures 7.Handling and Storage 8.Exposure Control/ Personal Protection 9.Physical & Chemical Properties 10.Stability & Reactivity 11.Toxicological Information 12.Ecological Information 13.Disposal Considerations 14.Transport Information 15.Regulatory Information 16.Other Information NOTE: All headings and sections must appear on SDS

58. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Safety Data Sheets Section 1 - Product Identifier Section 2 – Hazard(s) Identification GHS Classification Pictograms Signal Word Hazard Statement Precautionary Statement XYZ Chemical

59. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. SDS Quick Note Skull & Crossbones OR Unlike the requirement for Labels, Pictograms on SDSs may be represented like:

60. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Are you Prepared for the MSDS Churn?

61. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Manufacturer Distribution of SDSs June 1, 2015 - Manufacturers must begin using and providing newly formatted SDSs with their shipments to downstream users Manufacturers are still only required to provide new safety data sheets: 1)With initial shipments 2)With next shipment after an SDS has been updated 3)When requested by downstream users

62. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. No Chemical Left Behind Your Roadmap to Compliance with OSHA’s GHS Deadlines and Modified HCS

63. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Must-Dos and Haves Designate GHS Transition Leader Get and Stay Educated on GHS It's updated every 2 yrs. V5 was released in 2013. OSHA is already looking to align with V6, per 2014 Fall Unified AgendaIt's updated every 2 yrs. V5 was released in 2013. OSHA is already looking to align with V6, per 2014 Fall Unified Agenda Update HazCom Plan Train and Prepare Employees Ensure Existing Systems Can Handle Transition

64. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Start by taking Inventory of current Chemicals and SDSs

65. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Physically tour entire facility Jot down all products, including consumer products in non-consumer quantities (1 Wite-Out may not be covered by HazCom, but a storage closet of them might be.) Include: A: Product Name & Manufacturer B: Product Code, Supplier C: Storage Location Be sure to: Tour all areas (old storage areas, inside/outside, etc.) Include general supplies (paints, fertilizers, general cleaning supplies, etc.) Walk the Floor & Catalog

66. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Use Chemical Inventory List as Checklist to Manage Churn of Labels and MSDSs

67. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. ─What is your process for updating labels? ─Are your employees aware of that process? ─Who is responsible for updating your labels? ─Is that person checking to make sure labels aren't damaged or defaced? ─Do you need to purchase new equipment in order to print labels? Label Strategy know what to do about the old and the new

68. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Managing Old Labels “Employer is not responsible for updating labels on shipped containers, even if the shipped containers are labeled under HazCom 1994.” – OSHA Brief Hazard Communication Standard: Labels and Pictograms Employer responsibilities are limited to updating workplace labels to account for any newly identified hazards, and also training employees on those hazards.

69. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Have an MSDS to SDS Strategy know what to do with the old and the new

70. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. ─Who is responsible for managing your MSDS inventory? ─Is that person checking for HazCom GHS-formatted SDSs? ─Have employees been trained on the new SDS format? ─Are you continuing to train on the pre-GHS formats? ─How are you obtaining documents today / what is your plan for getting new SDSs? ─What happens when an SDS arrives in your inventory/ or what will happen when it doesn’t? ─Do your employees know what to do? ─Does your Written HazCom Program include your plans for managing documents during the GHS transition? MSDS to SDS Strategy

71. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. If you do not receive an SDS, request one ASAP Contact your supplier and request documents Show good faith effort Do not allow workers to use hazardous chemicals for which you have not received an SDS If you receive an SDS that is inadequate, you must request an appropriately completed one If your request does not produce the information needed, contact your local OSHA area office for assistance in obtaining the SDS Some suppliers provide SDSs for products that are not hazardous. These SDSs do not have to be maintained OSHA provided enforcement leniency to suppliers who meet certain criteria. Be aware that this affects your timelines for receiving updated labels and SDSs. Employer To-Dos for SDSs

72. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Managing Older Versions of MSDSs OSHA requires employers to retain exposure records by: Archiving safety data sheets or Maintaining a list of chemicals, + where + when chemicals were used or stored Requirement of 1910.1020 – Access to Employee Exposure to Medical Records

73. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Image Source: OSHA WebsiteOSHA Website NEW July 9, 2015 OSHA HazCom 2012 / GHS Enforcement Directive NEW: Specifies that employers must not require employees to perform Internet searches (i.e., Google and Yahoo) to view and obtain SDSs Employers may make SDSs available on a company website or contract with a Web-based SDS service provider Managing SDS library via employee Internet searches alone, is NOT compliant

74. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Image Source: OSHA WebsiteOSHA Website NEW July 9, 2015 OSHA HazCom 2012 / GHS Enforcement Directive NEW: Specifies that employers using the same product but from multiple manufacturers, must maintain corresponding SDSs for each product to be compliant Acetone 123 Company Acetone ABC Company Acetone XYZ Company Acetone 123 Company Acetone ABC Company Acetone XYZ Company

75. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Managing Older Versions of MSDSs OSHA’s HazCom doesn’t require archiving of SDSs However, 1910.1020 - Access to Employee Exposure to Medical Records, does require employers to retain exposure records, which can be achieved by … Archiving safety data sheets or Maintaining a list of chemicals, + where + when chemicals were used or stored

76. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. How is your HazCom Program affected by GHS?

77. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS Affects Entire HazCom Program 1.Written Plan Must reflect GHS changes. 2.Chemical Inventory List Must update if reclassification results in new hazardous chemicals. 3.Labels & Warnings Must update with new hazard info if warranted by reclassification process. Consider aligning with the new Shipped Label format. 4.Training Must include GHS changes to SDSs and Labels, any newly identified hazards, and changes to Written Plan. 5.Safety Data Sheets Mix of formats will exist in inventory. Should describe plan for managing these and ensure employee training on both.

78. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. GHS NEWS  Feb. 11, 2015 Canada adopted GHS at Federal level  Territories and Provinces must still adopt  WHMIS 2015 replaces WHMIS 1988  Hazardous Products Regulations (HPR) replaces Controlled Products Regulations (CPR) & Ingredient Disclosure List  Canada aimed to align as closely as possible to US, but there are still differences  3-Stage Transition  1st deadline May 31, 2017  Complete adoption by Dec. 1, 2018

79. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. MSDSonline GHS Answer Center http://www.msdsonline.com/blog/ghs-answer-center/ MSDSonline GHS 101 http://www.msdsonline.com/blog/ghs-101-links-to- useful-ghs-information/ Links to HazCom 2012/ GHS Info OSHA HazCom Info Page https://www.osha.gov/dsg/hazcom/index.html

80. Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners. Thank you! 1.888.362.2007 www.MSDSonline.com ComplianceExpert@MSDSonline.com For Questions or Presentation Copies: Chuck Haling chaling@msdsonline.com