GHS Hazard Commmunication Right-to-Understand Helping you comply with 29 CFR 1910.1200
Purpose of Hazard Communication (Hazcom) Classify the potential hazards of all chemicals. Ensure employees are aware of the dangers of all hazardous chemicals used by your company
Hazard Communication Five Elements 1) Written Program 2) Chemical Inventory 3) SDS File (formerly MSDS) 4) Chemical Labeling 5) Employee Training
Written HazCom Program Developed to meet regulatory requirements 29 CFR 1910.1200 Reviewed Annually Must be located in an area available for employee review or reference at all times! Where is your program located? Are you familiar with the program?
Introduction GHS Hazcom
Revised Hazard Communication Standard 29 CFR 1910.1200 March 26, 2012 - Aligned Hazard Communication Standard United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Published in the Federal Register in March 2012 77 FR17574
GHS GHS = Globally Harmonized System of Classification and Labeling of Chemicals Improve consistency of information in the workplace Harmonizing U.S. hazard communication rules with those used internationally.
OSHA HazCom GHS Two Significant Changes New label elements Standardized format for SDS (formerly MSDS)
What is GHS? Each country can voluntarily adopt it Countries without existing chemical hazard programs can utilize GHS to: Provide necessary protection for their workers Participate in international trade
Hazard Determination Means of Determination Manufacturer Labels SDS (formerly MSDS) Conduct Testing NFPA Diamond
Hazard Determination NFPA 704 HAZARD DIAMOND: Provides an immediate general sense of Hazards of a Material Severity of these Hazards as they relate to Emergency Response Blue Health Hazard Red Fire Hazard Yellow Reactivity Hazard White Special Hazard Associated Numbering 0 (low hazard)-4 (high hazard)
NFPA 704 vs HazCom 2012
Hazard Exposure Major means of exposure Inhale Ingest Absorb Inject Which would be your major concern?
Identified Hazards Methods of Detection Monitoring Through use of equipment Air quality, noise levels Daily Awareness Sight Smell Means of Protection The Big 3 Engineering Controls Administrative Controls PPE
Who is Responsible for What? Employers who Use chemicals: OSHA compliant HazCom program: 1. Written Hazard Communication Plan/Program A. Written Chemical Inventory (SDS) B. Collect and Maintain SDS C. Provide Access to Employees 2. Provisions for Secondary Container Labeling and Warnings 3. Provide Employee Training
Chemical Inventory List of chemicals or substances that are presently on site Updated as chemicals are added or discontinued By designated employee discuss responsible party! Reviewed for accuracy By designated employee List shall identify chemicals by the name on the chemicals associated SDS
Chemical Inventory What chemicals are to be included? Any chemical known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency Basically all chemicals/substances associated with production & maintenance;
Chemical Inventory The big question.. Is there anything that is not included? YES! Hazardous Waste, as defined by SWDA and amended by RCRA Tobacco and associated products Wood and associated products Articles, a manufactured item Food or beverage for consumption while at work Cosmetics Consumer products, where one can show it is used as intended by the manufacturer SWDA Solid Waste Disposal Act RCRA Resource Conservation Recovery Act
New Chemicals Inform employees of chemical and any associated hazards Train employees Proper handling techniques and protection methods Post chemical SDS for employee review Post within 5 days of chemical on site or before employee contact
Hazcom 2012 GHS Timeline Phased in December 1, 2013 Employers train all employees SDS format New Label elements June 1, 2015 Manufacturers & Distributers comply SDS requirements GHS Labeling June 1, 2016 Full implementation of GHS Likely not seeing full compliance from all vendors
Changes
Safety Data Sheets (SDS)
SDS Safety Data Sheets Each chemical on inventory list shall have corresponding SDS SDS required to be accessible by all employees during all shifts Are you seeing SDS with current shipments?
SDS Safety SDS Data Sheet Safety Data Sheets Reviewed for accuracy By designated employee Retained for a 30 year period Items no longer on site can be removed from the active chemical inventory list and SDS file Place in an archived file for the required 30 year retention As you receive SDS to replace MSDS, SDS may be disposed of.
SDS Safety SDSData Sheet - now have a specified 16-section format
SDS Safety Data Sheet 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
Workplace Labeling
Workplace Labeling Are there different types of labels? Yes 1. Supplier Labels 2. Workplace Labels
Workplace Labeling 1. Supplier Labels provided by the supplier will appear on all hazardous products received at a workplace 2. Workplace Labels hazardous product is produced (made) at the workplace and used in that workplace, hazardous product is transferred into another container, or a supplier label becomes lost or illegible (unreadable).
Workplace Labeling Regarding Bulk Shipments of Hazardous Chemicals - OSHA requires: 1. Either Labeling the Container OR 2. Transmitting the Required Label with shipping papers bill of lading or electronically so that it is immediately available to workers on the receiving end of a shipment.
Workplace Labels Employers may choose to label in-house containers with the same label that is on shipped containers for the chemical under the revised rule OR With label alternatives that meet the requirements of GHS Hazcom 2012
Workplace Labeling Labels on Incoming Containers Must not be removed or defaced unless immediately replaced
Workplace Labeling Must be prominently displayed Must be in English Other languages are permitted (in addition to English)
6 Elements of Labels GHS Hazcom 2012 Product/Chemical Identifier Supplier Identifier Hazard Pictogram(s) Signal Word Hazard Statement(s) Precautionary Information
GHS GHS Label Hazcom Elements 2012 Product Identifier Signal Word Pictogram Hazard Statement Precautionary Statement Identification Manufacturer Distributor Importer Workplace Labeling
Workplace Labeling GHS Hazcom 2012 1. Product/Chemical Identifier 2. Signal word 3. Hazard Statement 4. Precautionary Statement 5. Supplier Identifier 6. Hazard Pictogram(s)
Pictograms and Hazards There are nine pictograms under GHS and the new HCS requires eight of them the exception being environmental hazards which does not fall under OSHA jurisdiction HCS Hazard Communication Standard
GHS Hazards Classes: 1. Physical Hazards: Physical Properties Chemical Properties 2. Health Hazards Potential Health Effect
Physical Hazards main concerns Flammable catch fire easily Oxidizing cause or intensify a fire/explosion Gases Under Pressure may explode if heated Self-Reactive may react on their own to cause a fire/explosion Pyrophoric can catch fire spontaneously (very quickly) if exposed to air Self-Heating may catch fire if exposed to air. Differ from pyrophoric: ignite after a longer period of time or when in larger amounts
Physical Hazards main concerns Organic Peroxides may cause a fire/explosion if heated. Corrosive to metals may damage metals Combustible dust if dispersed in air, particles may catch fire or explode if ignited Simple asphyxiants gases that may displace oxygen in the air causing rapid suffocation.
GHS 2012 Label Pictograms Flame PHYSICAL HAZARDS: Flammable Self Reactive Pyrophoric Self-Heating Emits Flammable Gas Organic Peroxides
GHS 2012 Label Pictograms Flame over Circle PHYSICAL HAZARD: Oxidizers
GHS 2012 Label Pictograms Exploding Bomb PHYSICAL HAZARDS: Explosives Self Reactive Organic Peroxide
GHS 2012 Label Pictograms Gas Cylinder PHYSICAL HAZARD: Gases Under Pressure
Health Hazards main concerns Acute Toxicity fatal or harmful if inhaled, swallowed, or comes into contact with skin Skin corrosion cause severe skin burns Respiratory sensitization may cause breathing difficulties if inhaled Germ cell mutagenicity may cause genetic defects that can be passed on to future generations
Health Hazards main concerns Carcinogenicity may cause cancer Reproductive toxicity may damage fertility or unborn baby Aspiration hazard may be fatal if swallowed and enters airways Biohazardous infectious materials microorganisms that may cause infection
GHS 2012 Label Pictograms Skull & Crossbones HEALTH HAZARD: Acute Toxicity (Fatal or toxic)
GHS 2012 Label Pictograms Exclamation Mark HEALTH HAZARD: Skin & Eye Irritant Dermal Sensitizer Acute Toxicity (harmful) Transient Target Organ Effects
GHS 2012 Label Pictograms Corrosion HEALTH HAZARDS: Skin Corrosion Corrosive to Metals Serious Damage to Eye
GHS 2012 Label Pictograms Health Hazard HEALTH HAZARDS: Carcinogenicity Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity Aspiration Toxicity
GHS 2012 Label Pictograms Environmental (Not Mandatory) Environmental Toxicity
Employee Training
Employee Training 1910.1200(h)(1) Employers shall provide effective information and training on hazardous chemicals in their employees work area: 1. At the time of their initial assignment 2. Whenever a new chemical hazard is introduced into their work area.
Employee Training 1910.1200(h)(1) Chemical-specific information must always be available through labels and safety data sheets.
Consider Your Work Area. Are there any concerns relating to chemicals you may be exposed to through your job tasks? Please ask!
Mitigating the Hazard Handle chemicals with care. If unsure of a chemical s properties ask or refer to the SDS Wear the required and or recommended PPE for the task at hand If an emergency situation is likely, do not panic. Inform the supervisor, they can help handle the situation
Employee Training 1910.1200(h)(3) Employee training shall also include: Measures employees can take to protect themselves from chemical hazards Specific Procedures Appropriate Work Practices Personal Protective Equipment Emergency Procedures
Employee Training 1910.1200(h)(3) Employee training shall include: Methods and observations used to detect: presence or release of hazardous chemicals in the work area visual appearance or odor of hazardous chemicals