Section A: Purpose: Only terminology changes have been made within this section.

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1 In this document we will breakdown the changes that have been made to the Hazard Communication Standard of 1994 (HCS) in the new Hazard Communication Standard of 2012 (HCS 2012) which is meant to align the standard to meet the requirements of the Globally Harmonized System. This document will only discuss changes being made to the old standard as it relates to the Construction Industry. If it is not listed below it simply means it is still in place but no changes have been made. We have included additional information after each of the 3 sections where any major changes have occurred that will need to be referenced to conduct your training by no later than December 1, These sections will be colored purple for identification purposes and can be found at the end of the following: Section F: Labels and other forms of warning Section G: Safety Data Sheets Section A: Purpose: Only terminology changes have been made within this section. HCS 1994 HCS 2012 Required that the potential hazards of all chemicals are evaluated and information concerning any hazards and protective measures are communicated to employees. Why is this change important? Requires that the potential hazards of all chemicals are classified and information concerning any hazards and protective measures are communicated to employees. The purpose of GHS is to bring a more consistent approach to the means and methods used to identify the hazards of the chemicals they are handling. One of the KEY components of this new approach is the classification of a chemical to determine if it is hazardous or not. This process will become clearer as you review this document. Section B: Scope & Application: No significant changes have been made to this section as it pertains to complying with the new GHS requirements. One terminology change worth noting is the term Material Safety Data Sheet (MSDS) will know be called Safety Data Sheets (SDS). Section C Definitions: There have been several changes to this section. Some definitions have been modified, but the majority of changes have come with removal of terms and the installation of new ones. For the purpose of keeping this document user friendly, we will not list every new definition included in the standard. The following is a complete list of the terms that have been modified, deleted or added to the new standard. Added the following definitions: Classification, Hazard category, Hazard class, Hazard not otherwise classified, Hazard statement, Label elements, Pictogram, Precautionary statement, Product identifier, Pyrophoric Gas, Safety data sheet, Signal word, Simple asphyxiant, and Substance.

2 Deleted the following definitions: Combustible liquid, Compressed gas, Explosive, Flammable, Flashpoint, Hazard warning, Identity, Material safety data sheet, Organic peroxide, Oxidizer, Pyrophoric, Unstable (reactive), and Water-reactive. Revised the following definitions: Chemical, Chemical name, Hazardous chemical, Health hazard, Label, Mixture, Physical hazard, and Trade secret. HCS 2012: The following is a list of definitions of new or modified terms that have been selected by ORCPG to allow you to understand the changes made to this standard. Please note for a complete listing of definitions you will need to reference the new HCS Please contact your risk specialist for direction on where to find this information. "Chemical" means any substance, or mixture of substances. "Label" means an appropriate group of written, printed or graphic information elements concerning a hazardous chemical that is affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging. "Label elements" means the specified pictogram, hazard statement, signal word and precautionary statement for each hazard class and category. "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. "Hazard statement" means 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. Example: Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin. "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. "Precautionary statement - There are four types of precautionary statements: prevention (to minimize exposure); response (in case of accidental spillage or exposure emergency response, and first-aid); storage; and disposal. For example, a chemical presenting a specific target organ toxicity (repeated exposure) hazard would include the following on the label: Do not breathe dust/fume/gas/mist/ vapors/spray. Get medical advice/attention if you feel unwell.

3 Dispose of contents/ container in accordance with local/regional/ national and international regulations. "Hazard category" means the division of criteria within each hazard class, e.g., oral acute toxicity and flammable liquids include four hazard categories. These categories compare hazard severity within a hazard class and should not be taken as a comparison of hazard categories more generally. "Hazard class" means the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute toxicity. "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 in this section. In addition, classification for health and physical hazards includes the determination of the degree of hazard, where appropriate, by comparing the data with the criteria for health and physical hazards. "Hazard not otherwise classified (HNOC)" means an adverse physical or health effect identified through evaluation of scientific evidence during the classification process that does not meet the specified criteria for the physical and health hazard classes addressed in this section. This does not extend coverage to adverse physical and health effects for which there is a hazard class addressed in this section, but the effect either falls below the cut-off value/concentration limit of the hazard class or is under a GHS hazard category that has not been adopted by OSHA (e.g., acute toxicity Category 5). "Hazardous chemical" means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified. "Health hazard" means a chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard. The criteria for determining whether a chemical is classified as a health hazard are detailed in Appendix A to Health Hazard Criteria. "Physical hazard" means a chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive

4 to metal; gas under pressure; or in contact with water emits flammable gas. See Appendix B to Physical Hazard Criteria. "Product identifier" means the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS. "Pyrophoric gas" means a chemical in a gaseous state that will ignite spontaneously in air at a temperature of 130 degrees F (54.4 degrees C) or below. "Safety data sheet (SDS)" means written or printed material concerning a hazardous chemical that is prepared in accordance with paragraph (g) of this section. Section D: Hazard Classification: This section applies to chemical manufacturers and importers and generally does not apply to the construction trades who simply purchase and use chemicals at their workplace. Section E: Written Program: This section remains unchanged as OSHA has retained all components of the HCS 1994 within the new HCS Section F: Labels and other forms of warning: This paragraph has been extensively rewritten. Under this revised paragraph; chemical manufacturers and importers must provide a label that includes: the product identifier, supplier information which is to include name, address and phone number of manufacturer, importer or distributor; and the signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. The HCS 1994 does not require the use of pictograms, specific signal words, or precautionary statements. Please note that below is a summary of the changes to the new HCS 2012 version as it pertains to the Construction Industry. If it is not listed below, it simply does not apply or is still in place but hasn t changed. To see the complete list of the requirements set forth in this standard you will need to refer to the updated HCS HCS 1994 HCS 2012 Under the old standard the following information was required to be on the label: (f)(1) The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following The following is a list of the new requirements on what must be on the label: (f)(1) Labels on shipped containers. The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled,

5 information: (f)(1)(i) Identity of the hazardous chemical(s); (f)(1)(ii) Appropriate hazard warnings; and (f)(1)(iii) Name and address of the chemical manufacturer, importer, or other responsible party. (f)(5) Except as provided in paragraphs (f)(6) and (f)(7) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information: (f)(5)(i) Identity of the hazardous chemical(s) contained therein; and, (f)(5)(ii) Appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical. tagged or marked. Hazards not otherwise classified do not have to be addressed on the container. Where the chemical manufacturer or importer is required to label, tag or mark the following information shall be provided: (f)(1)(i) Product identifier; (f)(1)(ii) Signal word; (f)(1)(iii) Hazard statement(s); (f)(1)(iv) Pictogram(s); (f)(1)(v) Precautionary statement(s); and, (f)(1)(vi) Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party. (f)(2) The chemical manufacturer, importer, or distributor shall ensure that the information provided under paragraphs (f)(1)(i) through (v) of this section is in accordance with Appendix C to , for each hazard class and associated hazard category for the hazardous chemical, prominently displayed, and in English (other languages may also be included if appropriate). (f)(3) The chemical manufacturer, importer, or distributor shall ensure that the information provided under paragraphs (f)(1)(ii) through (iv) of this section is located together on the tag, label or mark. (f)(6) Workplace labeling. The employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either: (f)(6)(i) The information specified under paragraphs (f)(1)(i) through (v) of this section

6 for labels on shipped containers; or, (f)(6)(ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical. Employer Responsibilities Employers are responsible for maintaining the labels on the containers, including, but not limited to, tanks, totes, and drums. This means that labels must be maintained on chemicals in a manner which continues to be legible and the pertinent information (such as the hazards and directions for use) does not get defaced (i.e., fade, get washed off) or removed in any way. The employer is not responsible for updating labels on shipped containers, even if the shipped containers are labeled under HazCom The employer must re-label items if the labels are removed or defaced. However, if the employer is aware of newly-identified hazards that are not disclosed on the label, the employer must ensure that the workers are aware of the hazards as discussed below under workplace labels. Workplace Labels OSHA has not changed the general requirements for workplace labeling. Employers have the option to create their own workplace labels. They can either provide all of the required information that is on the label from the chemical manufacturer or, the product identifier and words, pictures, symbols or a combination thereof, which in combination with other information immediately available to employees, provide specific information regarding the hazards of the chemicals. If an employer has an in-plant or workplace system of labeling that meets the requirements of HazCom 1994, the employer may continue to use this system in the workplace as long as this system, in conjunction with other information immediately available to the employees, provides the employees with the information on all of the health and physical hazards of the hazardous chemical. This workplace labeling system may include signs, placards, process sheets, batch tickets, operating procedures, or other such written materials to identify hazardous chemicals. Any of

7 these labeling methods or a combination thereof may be used instead of a label from the manufacturer, importer or distributer as long as the employees have immediate access to all of the information about the hazards of the chemical. Workplace labels must be in English. Other languages may be added to the label if applicable. Employers may use additional instructional symbols that are not included in OSHA s HCS pictograms on the workplace labels. An example of an instructional pictogram is a person with goggles, denoting that goggles must be worn while handling the given chemical. Including both types of pictograms on workplace labels is acceptable. The same is true if the employer wants to list environmental pictograms or PPE pictograms from the HMIS to identify protective measures for those handling the chemical. Employers may continue to use rating systems such as National Fire Protection Association (NFPA) diamonds or HMIS requirements for workplace labels as long as they are consistent with the requirements of the Hazard Communication Standard and the employees have immediate access to the specific hazard information as discussed above. An employer using NFPA or HMIS labeling must, through training, ensure that its employees are fully aware of the hazards of the chemicals used. If an employer transfers hazardous chemicals from a labeled container to a portable container that is only intended for immediate use by the employee who performs the transfer, no labels are required for the portable container. Section G: Safety Data Sheets: Safety Data Sheets, previously referred to as Material Safety Data Sheets, will now require a 16-section format that is essentially the same as the ANSI standard for Hazardous Workplace Chemicals-Hazard Evaluation and Safety Data Sheets and Precautionary Labeling Preparation (ANSI Z400.1 & Z ), already familiar to U.S. employers. Paragraph (g) lists the sections in the order they are to be provided on the Safety Data Sheets. Please note that below is a summary of the changes to the new HCS 2012 version as it pertains to the Construction Industry. If it is not listed below, it simply does not apply or is still in place but hasn t changed. To see the complete list of the requirements set forth in this standard you will need to refer to the updated HCS HCS 1994 HCS 2012 (g) Material safety data sheets. (g) Safety data sheets. (g)(1) Chemical manufacturers and importers shall obtain or develop a material safety data sheet for each hazardous chemical they produce or import. Employers shall have a material safety data sheet in the workplace for each hazardous chemical which they use. (g)(1) Chemical manufacturers and importers shall obtain or develop a safety data sheet for each hazardous chemical they produce or import. Employers shall have a safety data sheet in the workplace for each hazardous chemical which they use.

8 (g)(2) Each material safety data sheet shall be in English (although the employer may maintain copies in other languages as well), and shall contain at least the following information: (g)(2)(i) The identity used on the label, and, except as provided for in paragraph (i) of this section on trade secrets: (g)(2)(i)(a) If the hazardous chemical is a single substance, its chemical and common name(s); (g)(2)(i)(b) If the hazardous chemical is a mixture which has been tested as a whole to determine its hazards, the chemical and common name(s) of the ingredients which contribute to these known hazards, and the common name(s) of the mixture itself; or, (g)(2) (i)(c) If the hazardous chemical is a mixture which has not been tested as a whole: (g)(2)(i)(c)(1) The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise 1% or greater of the composition, except that chemicals identified as carcinogens under paragraph (d) of this section shall be listed if the concentrations are 0.1% or greater; and, (g)(2)(i)(c)(2) The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise less than 1% (0.1% for carcinogens) of the mixture, if there is evidence that the ingredient(s) could be released from the mixture in concentrations which would exceed an established OSHA permissible exposure limit or ACGIH Threshold Limit Value, or could present a health risk to employees; and, (g)(2)(i)(c)(3) The chemical and common name(s) of all ingredients which have been (g)(2) The chemical manufacturer or importer preparing the safety data sheet shall ensure that it is in English (although the employer may maintain copies in other languages as well), and includes at least the following section numbers and headings, and associated information under each heading, in the order listed (See Appendix D to Safety Data Sheets, for the specific content of each section of the safety data sheet): (i) Section 1, Identification; (ii) Section 2, Hazard(s) identification; (iii) Section 3, Composition/information on ingredients; (iv) Section 4, First-aid measures; (v) Section 5, Fire-fighting measures; (vi) Section 6, Accidental release measures; (vii) Section 7, Handling and storage; (viii) Section 8, Exposure controls/personal protection; (ix) Section 9, Physical and chemical properties; (x) Section 10, Stability and reactivity; (xi) Section 11, Toxicological information. (xii) Section 12, Ecological information; (xiii) Section 13, Disposal considerations; (xiv) Section 14, Transport information; (xv) Section 15, Regulatory information; and (xvi) Section 16, Other information, including

9 determined to present a physical hazard when present in the mixture; (g)(2)(ii) Physical and chemical characteristics of the hazardous chemical (such as vapor pressure, flash point); (g)(2)(iii) The physical hazards of the hazardous chemical, including the potential for fire, explosion, and reactivity; (g)(2)(iv) The health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical; date of preparation or last revision. Note 1 to paragraph (g)(2): To be consistent with the GHS, an SDS must also include the headings in paragraphs (g)(2)(xii) through (g)(2)xv) in order. Note 2 to paragraph (g)(2): OSHA will not be enforcing information requirements in sections 12 through 15, as these areas are not under its jurisdiction. (g)(2)(v) The primary route(s) of entry; (g)(2)(vi) The OSHA permissible exposure limit, ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the material safety data sheet, where available; (g)(2)(vii) Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Annual 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 by OSHA; (g)(2)(viii) Any generally applicable precautions for safe handling and use which are known to the chemical manufacturer, importer or employer preparing the material safety data sheet, including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for clean-up of spills and leaks; (g)(2)(ix) Any generally applicable control measures which are known to the chemical

10 manufacturer, importer or employer preparing the material safety data sheet, such as appropriate engineering controls, work practices, or personal protective equipment; (g)(2)(x) Emergency and first aid procedures; (g)(2)(xi) The date of preparation of the material safety data sheet or the last change to it; and, (g)(2)(xii) The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary. The Hazard Communication Standard (HCS) (29 CFR (g)), revised in 2012, requires that the chemical manufacturer, distributor, or importer provide Safety Data Sheets (SDSs) (formerly MSDSs or Material Safety Data Sheets) for each hazardous chemical to downstream users to communicate information on these hazards. The information contained in the SDS is largely the same as the MSDS, except now the SDS are required to be presented in a consistent user-friendly, 16-section format. Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures (e.g., fire fighting). This information should be helpful to those that need to get the information quickly. Sections 9 through 11 and 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision. The SDS must also state that no applicable information was found when the preparer does not find relevant information for any required element. The SDS must also contain Sections 12 through 15, to be consistent with the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS), but OSHA will not enforce the content of these sections because they concern matters handled by other agencies. Section H: Training Requirements: The provisions in paragraph (h) indicate that the new label, safety data sheet formats and presentation of information must be discussed in training. All employers will be required to conduct additional training to ensure that their employees are

11 familiar with the new standardized labels and safety data sheets. Otherwise, the training provisions remain the same as the HCS Please note that below is a summary of the changes to the new HCS 2012 version as it pertains to the Construction Industry. If it is not listed below, it simply does not apply or is still in place but hasn t changed. To see the complete list of the requirements set forth in this standard you will need to refer to the updated HCS HCS 1994 HCS 2012 (h) Employee information and training. (h) Employee information and training. (h)(1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets. Training shall include at least: (h)(3)(ii) The physical and health hazards of the chemicals in the work area; (h)(3)(iv) The details of the hazard communication program developed by the employer, including an explanation of the labeling system and the material safety data sheet, and how employees can obtain and use the appropriate hazard information. (h)(1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets. Training shall include at least: (h)(3)(ii) The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area; (h)(3)(iv) The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.

12 The list below contains the minimum required topics for the training that must be completed by December 1, Training on label elements must include information on: Type of information the employee would expect to see on the new labels, including the: Product identifier: how the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS (Identification). Signal word: used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. There are only two signal words, Danger and Warning. Within a specific hazard class, Danger is used for the more severe hazards and Warning is used for the less severe hazards. There will only be one signal word on the label no matter how many hazards a chemical may have. If one of the hazards warrants a Danger signal word and another warrants the signal word Warning, then only Danger should appear on the label. Pictogram: OSHA s required pictograms must be in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame sufficiently wide enough to be clearly visible. A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label. OSHA has designated eight pictograms under this standard for application to a hazard category. Hazard statement(s): describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. For example: Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin. All of the applicable hazard statements must appear on the label. Hazard statements may be combined where appropriate to reduce redundancies and improve readability. The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it. Precautionary statement(s): means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling. Name, address and phone number of the chemical manufacturer, distributor, or importer

13 How an employee might use the labels in the workplace. For example: Explain how information on the label can be used to ensure proper storage of hazardous chemicals. Explain how the information on the label might be used to quickly locate information on first aid when needed by employees or emergency personnel. General understanding of how the elements work together on a label. For example: Explain that where a chemical has multiple hazards, different pictograms are used to identify the various hazards. The employee should expect to see the appropriate pictogram for the corresponding hazard class. Explain that when there are similar precautionary statements, the one providing the most protective information will be included on the label. Training on the format of the SDS must include information on: Standardized 16-section format, including the type of information found in the various sections For example, the employee should be instructed that with the new format, Section 8 (Exposure Controls/Personal Protection) will always contain information about exposure limits, engineering controls and ways to protect yourself, including personal protective equipment. How the information on the label is related to the SDS For example, explain that the precautionary statements would be the same on the label and on the SDS.

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