1. Hazard Communication Program / Globally Harmonized System American Safety & Health, Inc. George S. Kunz Executive V. P. Cell # 614/257-9545

2. Haz Com / GHS Overview  What is it?  29 CFR 1910.1200 & 1926.59  How will GHS change your HazCom Program?  When will this happen?  What do you need to do now?

3. What is GHS?  The Globally Harmonized System (GHS) is an international approach to hazard communication  United Nations' document on Globally Harmonized System of Classification and Labeling of Chemicals (purple book)  Harmonizes hazardous chemical classification and communication (Labels and SDS)

4. Hazard Communication and GHS Will everything change?  Many program elements are similar, but not exactly alike  Not a total re-write of the standard  Two most prevalent changes: Hazard ClassificationHazard Classification Health and Physical HazardsHealth and Physical Hazards  Hazard Communication LabelsLabels Safety Data SheetsSafety Data Sheets

5. Haz Com History Haz Com History  Late 1970’s-- “Right to Know”  Early 1980’s--City Ordinances/State Laws  1983—Hazard Communication “HCS” enacted  1994– “HCS 1994” Federal Law revised  March 2012– “HCS 2012”  Globally Harmonized System  OSHA revises HCS to align with GHS  Right to Know to Right to Understand

6. Why Modify the HCS?  The frame work won’t change.  Improve quality Consistency of hazard information.  Align HCS with GHS will enhance workers understanding of hazards.  Reduces trade barriers.

7. What’s Next ? Effective Completion Date Requirement(s)Who December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format. “PAST DUE” Employers

8. What’s Next? Effective Completion Date Requirement(s)Who June 1, 2015* December 1, 2015 Compliance with all modified provisions of this final rule, except:. “PAST DUE” The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label Chemical manufacturers, importers, distributors and employers *This date coincides with the EU implementation date for classification of mixtures

9. What’s Next? Effective Completion Date Requirement(s)Who June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers

10. What’s Next ? Effective Completion Date Requirement(s)Who Transition Period to the effective completion dates noted above May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both Chemical manufacturers, importers, distributors, and employers

11. Current HazCom Citations StandardSubject 1910.1200 (e) Failure to develop a written program 1910.1200 (f) Failure to label containers 1910.1200 (g) Failure to have an MSDS for each hazardous chemical 1910.1200 (h) Failure to train employees

12. Requirements of the Standard SDS Labeling Written Written Program Program InventoryTraining

13. HOW TO CONDUCT A WORKPLACE INVENTORY  Identify Materials By Department.  Note Operations Performed Dept. By Dept.  Look at Labeling.  Identify Material by Processes.  Look at materials used by other Contractors.  Look at materials on site and in storage.  Look in all areas.

14. HAZARDOUS MATERIAL INVENTORY

15. Safety Data Sheets Purpose—show comprehensive chemical safety information SDS for each hazardous material Readily Accessible/complete/retain Provide Copies to employees when requested When working at different locations 16 section format Someone responsible

16. Safety Data Sheets Appendix D  There are 16 sections in the safety data sheet.  Each section has a specified sequence and minimum information requirements.  OSHA will not enforce sections 12-15 that require information outside OSHA’s jurisdiction  Based on ANSI Z400

17. Safety data sheet sections and sequence 1. Identification 2. Hazard(s) identification 3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling and storage 8. Exposure Controls/PPE 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 Info - Date prepared/revised * Regulated by other Agencies

18. Labeling  Purpose—immediate warning  Identity, hazards, and safe use  All containers are labeled  Types:  GHS Labels  Linked to Hazard Class and Category  Company labels  HMIS, NFPA  Someone responsible Zip Cleaner

19. At the source of potential contact with a chemical, a container label provides: important information about how to handle that chemical safely. While they’re not as informative as Safety Data Sheets, it’s critical that an appropriate identifying label is affixed to any container that holds hazardous chemicals. Labeling

20. 2 Basic “Uniform Labels” Prior to 2012  NFPA—National Fire Protection Association  HMIS—Hazardous Material Identification System Both types must identify the chemical name and hazards

21. Workplace Labeling of Chemicals  If chemicals are placed in another container, this new container must have a label  Workplace labels –alternative labels for secondary labels are allowed  Portable container exemption

22. Chemical Labels GHS Format How will labels change under the revised Hazard Communication Standard?  Labels will cover physical, health and environmental hazards  Pictograms- Nine different ones  Signal Words - Danger and Warning  Hazard Statement -  Precautionary Statement -

23. Health Hazard 4-Deadly 3-Extremely Hazardous 2-Hazardous 1-Slightly Hazardous 0-Normal material Specific Hazard Oxidizer OXY Acid ACID Alkali ALK Corrosive COR Use NO WATER W Radiation Hazard Chemical Name Fire Hazard Flash Points 4-Below 73 F 3-Below 100 F 2-Below 200 F 1-Above 200 F 0-Will not burn Reactivity 4-May detonate 3-Shock and heat may detonate 2-Violent chemical change 1-Unstable if heated 0-Stable ol NFPA Label (blue) (red) (yellow) (white)

24. Personal Protective Equipment Reactivity Flammability Health HMIS LABEL Chemical Name:______________________________ (blue) (red) (yellow) (white)

25. Workplace Labeling  Example: Flammable liquids GHS  Category 1: Extremely flammable liquid and vapour  Category 2: Highly flammable liquid and vapour  Category 3: Flammable liquid and vapour  Category 4: Combustible liquid While the hazard category number doesn’t appear on the label, consider: GHS CategoryHMIS/NFPA 704 1- Highest4- Extreme 2- High 3- High 3- Medium2- Moderate 4- Low1- Slight

26. Pictograms / Symbols

27. Symbols for Pictograms Corrosive Skin/Eye Metals

28. Symbols for Pictograms Gas Under Pressure

29. Symbols for Pictograms Irritant Dermal sensitizer Acute toxicity (harmful) Narcotic effects Respiratory tract Irritation

30. Symbols for Pictograms Flammable Self reactive Pyrophorics Self-heating Emits flammable gas Organic peroxides

31. Symbols for Pictograms Explosive

32. Symbols for Pictograms Environmental Hazard

33. Symbols for Pictograms Health Hazard “Star Man” Acute Toxicity Carcinogen Respiratory sensitizer Reproductive toxicity Target organ toxicity Mutagenicity Aspiration toxicity

34. Symbols for Pictograms Oxidizer

35. Symbols for Pictograms Acute toxicity (severe)

37. Aspects of OSHA’s GHS Approach Terminology has been changed to be consistent with the GHS where necessary Terminology has been changed to be consistent with the GHS where necessary ◦ Most common changes are “hazard classification” (rather than hazard determination) and “safety data sheet” (rather than material safety data sheet) GHS provisions have been put into OSHA mandatory language GHS provisions have been put into OSHA mandatory language Bulk of technical requirements in Appendices Bulk of technical requirements in Appendices

38. Hazard Classification  Each health and physical hazard is a “hazard class”  A “hazard class” may also be sub-divided into several “hazard categories” based on the degree of severity of the hazard  This is the concept of classification— determining both that there is a hazard, and what the severity is

39. Health Hazard Classes— Appendix A  Acute toxicity  Skin corrosion/Irritation  Serious eye damage/eye Irritation  Respiratory or skin sensitization  Germ cell mutagenicity  Carcinogenicity  Reproductive toxicology  Target organ systemic toxicity - single exposure  Target organ systemic toxicity - repeated exposure  Aspiration toxicity

40. Physical Hazard Classes Appendix B  Explosives  Flammable gases  Flammable aerosols  Organic peroxide  Gases under pressure  Flammable liquids  Flammable solids  Self-reactive substances  Pyrophoric liquids  Pyrophoric solids  Self-heating substances  Emits flammable gases on contact with water  Oxidizing liquids, gas, & solids  Corrosive to metals

41. Hazard Communication Training Employers shall provide employees with effective information and training on hazardous chemicals at;  The time of initial assignment  Whenever a new hazard is introduced  When transferring  When returning from extended leave

42. Haz Com Training for SDS  The material safety data sheet (MSDS) is now a safety data sheet (SDS).  Explain the sequence of order in regard to the information on the SDS.  Explain the labeling system (for received materials as well as the workplace labeling system).

43. General Training  Hazard Communication Standard  Employer’s Written Program  Location/Availability Of Written Program & SDS  How to read labels & SDS’s

44. Specific Training  Characteristics - How to detect  Health & Physical Hazards  Work practices or SOPs  Emergency action plans  Personal Protective Equipment (PPE)  Non-routine tasks  Industrial Hygiene monitoring results

45. Written program:  Developed, implemented, and maintained Chemical inventoryChemical inventory Safety data sheetsSafety data sheets LabelingLabeling TrainingTraining Misc.Misc.  Non-Routine Tasks  Piping Systems  Contractors/Multi-Employer Worksites

46. Appendices Appendix A, Health Hazard Criteria (Mandatory) (NEW) Appendix B, Physical Hazard Criteria (Mandatory) NEW) Appendix A, Health Hazard Criteria (Mandatory) (NEW) Appendix B, Physical Hazard Criteria (Mandatory) NEW) Appendix C, Allocation of Label Elements (Mandatory) (NEW) Appendix C, Allocation of Label Elements (Mandatory) (NEW) Appendix D, Safety Data Sheets (Mandatory) (NEW) Appendix D, Safety Data Sheets (Mandatory) (NEW) Appendix E, Definition of “Trade Secret” (Mandatory) Appendix E, Definition of “Trade Secret” (Mandatory) Appendix F, Guidance for Hazard Classifications re: Carcinogenicity (Non-Mandatory) (NEW) Appendix F, Guidance for Hazard Classifications re: Carcinogenicity (Non-Mandatory) (NEW)

47. Implementation Dates; 1. Employers shall train on new labels elements and SDS by December 1, 2013. 2. Chemical manufacturers, importers, distributors shall be in compliance with changes by June 1, 2015. 3. After December 1, 2015, no containers should be shipped with out labels updated. 4. Employers shall have updated labeling, HCP & training on the new program, June 1, 2016. 5. Chemical Mfg., importers, distributors & employers may comply with the original 1910.1200 or the revised standard as of October, 1, 2011.

48. Questions? ? ? ? ? ? ?