New OSHA Training Requirements for the Revised HAZ-Com Standard 2014 Presented by Aircare FACTS Training 1 1
New OSHA Training Requirements for the Revised HAZ-Com Standard For many years, OSHA has provided information to employers in the form of its Hazard Communication Standard (HCS). This information and labeling system is intended to provide employees necessary information about dangerous or potentially hazardous materials they encounter in the workplace. OSHA has now revised the HCS to more closely align with the internationally recognized GHS (Globally Harmonized System). Because of this, it is necessary to become familiarized with this new system. This short, informational presentation will take you through the changes that allow you to be in compliance with this new standard. 2 2
New OSHA Training Requirements for the Revised HAZ-Com Standard December 1 st, 2013 Training Requirements for the Revised Hazard Communication Standard (From OSHA implementation information) There are two significant changes contained in the revised standard require the use of new labeling elements and a standardized format for Safety Data Sheets (SDSs), formerly known as, Material Safety Data Sheets (MSDSs). The new label elements and SDS requirements will improve worker understanding of the hazards associated with the chemicals in their workplace. To help companies comply with the revised standard, OSHA is phasing in the specific requirements over several years (December 1, 2013 to June 1, 2016). 4 4
Why Train Now? Why is the training being done now? Labels and SDSs are changing Information is being standardized and specified All suppliers of a chemical should communicate hazards in the same way Role of labels Immediate source of information New labels have more information What is a label element? Each label element should be explained Hazard class should also be addressed to help understand the label elements Example label should be provided Safety Data Sheet (SDS) Format (sections) Information found on SDSs Requirements (accessibility and use) 6 6
Why Train Now? While new labels and SDSs are required to be provided by manufacturers and importers by June 1, 2015, employers have until June 1, 2016 to make adjustments to their workplace programs for any new hazards identified as a result of the transition to the GHS system If workplace labeling changes (i.e., alternative systems are used), workers will have to be trained on this as well timing will depend on when the workplace labeling is updated 7 7
What is the GHS? International Harmonization- A Recognized Standard The GHS (Globally Harmonized System of Classification and Labeling of Chemicals) was enacted by the United Nations beginning in 1992. Since that time it has become the recognized standard world-wide to categorize dangerous chemicals. Prior to the GHS, there were literally dozens of ways companies and importers would identify chemicals. Often the same chemical would be labeled as dangerous by one manufacturer and deadly by another! 8 8
What s so important about labels? Labels are the immediate source of information on a chemical New labels will have more information than current labels There may also be additional information (known as supplemental information) on the label that is not required the required information should be presented together on the label 9 9
What is a label element? Label element means the specified pictogram(s), hazard statement(s), signal word and precautionary statement(s) for each hazard class and category. Under the new OSHA standard, chemical manufacturers must include several elements on their product labels. Additionally, employers must train their employees on these elements to ensure proper storage of hazardous chemicals, quick location of first aid information and understanding how the various label elements work together to explain multiple hazards. For example Danger means a more severe hazard within a hazard class than Warning which is for the less severe hazard. 10 10
So, what must be included on the label...? There are 5 required label elements... Product identifier. Chemical name, code number or batch number. Signal word. Indicates the severity level of hazard. Only the words Warning or Danger are allowed. Pictogram. OSHA has designated eight pictograms that can be used in this hazard category. Hazard statement(s). Describes the nature of the hazard(s) of a chemical, including the degree of hazard. Precautionary statements. Recommends measures to take to minimize or prevent adverse effects resulting from exposure to, storage or handling of a hazardous chemical. 11 11
Product Identifier The Product Identifier is simply how the product needs to be identified. It will contain the chemical name and a code or batch number. This information if provided by the manufacturer. DANGER or WARNING Signal Word Signal word indicates a word used to alert the reader to a potential hazard on the label. There are 2 signal words that will be used. They are DANGER and WARNING. Danger is used for the more severe hazards, while warning is used for the less severe. 12 12
Pictogram 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 Each pictogram must be in the shape of a red square set at a point and include a black symbol on a white background. There are 8 required pictograms. The 9th, "Environmental" may be listed, but it is not required. HCS Pictograms and Hazards 13 13
Hazard Statement Precautionary Statement Hazard statement is 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. Examples: Fatal if swallowed (Acute Oral Toxicity) Causes damage to kidneys through repeated exposure Precautionary statement 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 Example: Do not eat, drink, or smoke when using this product Example: Keep container tightly closed The statements assigned to a chemical address the following four areas Prevention Response Storage Disposal 14 14
How to use the label From information contained on the label, you should be able to: 1) Ensure proper storage of chemical. 2) Explain first aid procedures. 3) Verify multiple hazards of a chemical 4) Identify the difference in precautionary statements. OSHA has updated the requirements for labeling of hazardous chemicals under its Hazard Communication Standard (HCS). As of June 1, 2015, all labels will be required to have pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification. A sample revised HCS label, identifying the required label elements, is shown on the right. Supplemental information can also be provided on the label as needed. For more information: QUICK CARDTM Hazard Communication Standard Labels (800) 321-OSHA (6742) www.osha.gov CODE Product Name Company Name Street Address City State Postal Code Country Emergency Phone Number } } Keep container tightly closed. Store in a cool, well-ventilated place that is locked. Keep away from heat/sparks/open flame. No smoking. Only use non-sparking tools. Use explosion-proof electrical equipment. Take precautionary measures against static discharge. Ground and bond container and receiving equipment. Do not breathe vapors. Wear protective gloves. Do not eat, drink or smoke when using this product. Wash hands thoroughly after handling. Dispose of in accordance with local, regional, national, international regulations as specified. Product Identifier In Case of Fire: use dry chemical (BC) or Carbon Dioxide (CO2) fire extinguisher to extinguish. First Aid If exposed call Poison Center. If on skin (or hair): Take off immediately any contaminated clothing. Rinse skin with water. Supplier Identification } Supplemental SAMPLE LABEL Precautionary Statements Hazard Pictograms Signal Word Danger Highly flammable liquid and vapor. May cause liver and kidney damage. } Information Directions for Use Hazard Statements Fill weight: Lot Number: Gross weight: Fill Date: Expiration Date: OSHA 3492-02 2012 15 15
In addition to product labels, you may see transport labels as well. These are used primarily by shippers and importers and identify the risk, toxicity, flammability of transported materials. Examples of Transport Labels 16 16
The SDS (Safety Data Sheet) Along with the new labels, there is a new format for the SDS (Safety Data Sheet). Formally known as the MSDS, the new SDS has a standardized 16-section format. It is designed to present a more complete picture of the chemical, personal protective equipment necessary, what to do if exposed,etc. Product XYZ 17 17
Role of the Safety Data Sheet --It is a detailed source of information about the chemical It is written for many audiences, including shippers and end users It is a definitive reference to help ensure a chemical is handled and stored safely The new format is largely the same as previous versions Retailers should update their SDS sheets (and chemical inventory lists) going forward as part of your hazard communication program as new SDS sheets are received from chemical manufacturers (effective compliance deadline is June 1, 2015). Note that the effective deadline for updating workplace labeling and hazard communication program as necessary is June 1, 2016. 18 18
Safety Data Sheet Format New safety data sheets will be organized using a specified order of information The required information will appear in the same sections of an SDS regardless of the supplier The most important information will be listed in the first sections of the SDS 19 19
SDS Sections 1. Identification: Identifier; manufacturer or distributor name, contact info; recommendations/restrictions. 2. Hazard(s): Includes all hazards regarding the chemical; required label elements. 3. Composition/ingredients: Chemical ingredients; trade secret claims. 4. First-aid measures: Symptoms/ effects, acute, delayed; required treatment. 5. Fire-fighting measures: Suitable extinguishing techniques, equipment; chemical hazards from fire. 6. Accidental release measures: Emergency procedures; protective equipment; containment and cleanup. 7. Handling and storage: precautions for safe handling and storage, including incompatibilities. 8. Exposure control/personal protection: lists OSHA's Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE). The Hazard Communication Standard (HCS) requires chemical manufacturers, distributors, or importers to provide Safety Data Sheets (SDSs) (formerly known as Material Safety Data Sheets or MSDSs) to communicate the hazards of hazardous chemical products. As of June 1, 2015, the HCS will require new SDSs to be in a uniform format, and include the section numbers, the headings, and associated information. 20 20
SDS Sections-continued 9. Physical and chemical properties: lists the chemical's characteristics. 10. Stability/Reactivity: lists chemical stability and possibility of hazardous reactions. 11. Toxicological Info: Routes of exposure; symptoms, acute and chronic effects; toxicity. 12. Ecological Info: Effect on the environment. 13. Disposal Considerations: Special guidelines on removal. 14. Transport Info: Special transport requirements. 15. Regulatory Info: Any special regulations pertaining to chemical. 16. Other Info: Date of last revision. 21 21
Additional Q&A For which chemicals do I need to have an SDS? Employers must have a GHS-style, 16 section SDS for each chemical which is considered to be a health or physical hazard, except for those products specifically exempted under the hazcom regulation at 1910.1200(b)(6). What is a health hazard? OSHA defines "health hazard" as "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." What is a physical hazard? OSHA defines a "physical hazard" as "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 to metal; gas under pressure; or in contact with water emits flammable gas." Do I need to have an SDS for commercial products like "Windex?" You are not required to have SDSs for household consumer products when the products are used in the workplace in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience. This exemption is based on the use of his product in the workplace. Can SDSs be kept on a computer to meet the accessibility requirements of HazCom? OSHA says in 1910.1200(g)(8) that it is permissible to provide access to SDSs electronically in the employee's work area provided the employee is trained on accessing the data. Safety data sheets may also be kept at the primary workplace facility when the employee travels as part of their job. In this situation, the employer shall ensure that employees can immediately obtain the required information in an emergency. 23 23
Additional Q&A What is the most common way contamination enters the body? Inhalation remains the most common route of transmission. Protecting against fumes or aerosolized particles is very important, through the use of PPE (masks) or ventilation. Under the GHS severity scale of 1-5, which is more severe? GHS uses a 1-5 severity scale with 1 being the most dangerous. Category 1 = severe hazard Category 2 = serious Category 3 = moderate Category 4 = slight Category 5 = minimal What can you do to help reduce or eliminate hazards? Remove the hazard: Use a less toxic alternative Engineering controls: Ventilation, hoods, machine guards etc. Administrative controls: Procedures and training PPE: Your last line of defense 24 24
QUICK CARD Hazard Communication Standard Pictogram As of June 1, 2015, the Hazard Communication Standard (HCS) will require pictograms on labels to alert users of the chemical hazards to which they may be exposed. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s). The pictogram on the label is determined by the chemical hazard classification. HCS Pictograms and Hazards Health Hazard Flame Exclamation Mark TM Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity Flammables Pyrophorics Self-Heating Emits Flammable Gas Self-Reactives Organic Peroxides Irritant (skin and eye) Skin Sensitizer Acute Toxicity (harmful) Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (Non-Mandatory) Gas Cylinder Corrosion Exploding Bomb Gases Under Pressure Skin Corrosion/ Burns Eye Damage Corrosive to Metals Explosives Self-Reactives Organic Peroxides Flame Over Circle Environment Skull (Non-Mandatory) and Crossbones Oxidizers Aquatic Toxicity Acute Toxicity (fatal or toxic) For more information: U.S. Department of Labor www.osha.gov (800) 321-OSHA (6742) OSHA 3491-02 2012
OSHA has updated the requirements for labeling of hazardous chemicals under its Hazard Communication Standard (HCS). As of June 1, 2015, all labels will be required to have pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification. A sample revised HCS label, identifying the required label elements, is shown on the right. Supplemental information can also be provided on the label as needed. For more information: QUICK TM CARD Hazard Communication Standard Labels (800) 321-OSHA (6742) www.osha.gov CODE Product Name Company Name Street Address City State Postal Code Country Emergency Phone Number } } Keep container tightly closed. Store in a cool, well-ventilated place that is locked. Keep away from heat/sparks/open flame. No smoking. Only use non-sparking tools. Use explosion-proof electrical equipment. Take precautionary measures against static discharge. Ground and bond container and receiving equipment. Do not breathe vapors. Wear protective gloves. Do not eat, drink or smoke when using this product. Wash hands thoroughly after handling. Dispose of in accordance with local, regional, national, international regulations as specified. Product Identifier In Case of Fire: use dry chemical (BC) or Carbon Dioxide (CO2) fire extinguisher to extinguish. First Aid If exposed call Poison Center. If on skin (or hair): Take off immediately any contaminated clothing. Rinse skin with water. Supplier Identification } Supplemental SAMPLE LABEL Precautionary Statements Hazard Pictograms Signal Word Danger Highly flammable liquid and vapor. May cause liver and kidney damage. } Information Directions for Use Hazard Statements Fill weight: Lot Number: Gross weight: Fill Date: Expiration Date: OSHA 3492-02 2012
Question Review With Answers Which hazard group(s) does the GHS recognize? A) Physical Hazards B) Health Hazards C) Environmental Hazards D) All of the Above-All are part of the GHS hazard standard What is the most common way a contaminated material enters the body? A) Absorption B) Injection C) Inhalation-The respiratory system is the #1 route of entry for chemicals What section of the SDS deals with first aid measures? A) 1 B) 3 C) 4-Definitely a section you need to be familiar with in a emergency! Which of the following is effected by the new Haz Com standard? A) Label requirements B) SDS format C) Training requirements D) All of the above-training on Labels and SDS changes is the first OSHA compliance requirement The new HCS requires all employees to be re-trained in all aspects of Hazardous Materials? A) True B) False-Only training on new labels and SDS changes are required at this time The pictogram shown below illustrates what hazard? A) Corrosion Hazard B) Health Hazard C) Oxidizer D) None of the above
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