Global Harmonization and OSHA WHAT YOU NEED TO KNOW (AND WHAT YOU DON’T)

Rob Harrington, Ph.D. Director of Regulatory Blyth NCA Meeting Las Vegas, NV April 6, 2010

Topics • What is global harmonization (commonly known as the Global Harmonization Standard or GHS)? • Why do I need to know? • How does it work? • What do I have to do?

What is GHS? • It is the Globally Harmonized System of Classification and Labeling of Chemicals – Defines health, physical and environmental hazards – Establishes classification rules for substances and mixtures using available data – Establishes a common hazard communication method recognized worldwide – Explains how to apply the system – Supplies the building blocks for regulations to assist countries in developing their own laws

History of GHS • Developed from an international mandate from the UN Conference on Environment and Development (Earth Summit) in 1992 • Designed to be a globally harmonized hazard classification and labeling system (including material safety data sheets, labels and easily understandable and universally recognized pictograms) • GHS is not a regulation, but a guidance document that must be incorporated into national regulations country by country

Why is There a Need for a Globally Harmonized System? • Classifications of a single product differ from country to country and even within a country • For example, a single material may be classified as: “Toxic” in the U.S. under CPSC regulations “Harmful” in Canada under Health Canada Regulations Unclassified (not toxic) under OSHA regulations

Why Do I Need to Know About GHS • OSHA is adopting the principles of GHS through the Hazard Communication Standard (29 CFR 1910.1200.) • This will significantly change the information on labels and MSDSs seen for the last 25 years (this is the first major change to Hazcom since 1985!) • Canada is still developing their GHS system and it is not expected to be published until sometime in late 2011 • The EU has begun to implement these requirements through the Classification, Labeling and Packaging (CLP) regulations (12/1/10 – 6/1/15) • CPSC harmonization program is “missing in action” at the moment

OSHA and GHS • In September 2009 issued a notice of proposed rulemaking on GHS; final regulation to be out soon • Requires all workplace materials be reevaluated under the new system • Requires new labels to be developed • Requires new mandatory 16 section “Safety Data Sheets” (SDS) • Requires worker re-training under Hazcom

How Does GHS Work? • GHS specifies certain environmental, health and physical hazards you must assess and classify for each material or product • GHS establishes a very detailed and complex process to classify materials so the classifications are consistent worldwide • All labels and SDSs need to comply with GHS standards which are based on the results of the new GHS classification criteria

Health/Environmental Hazards • • • • • • • • • • •

Acute toxicity Skin corrosion/irritation Serious eye damage/eye irritation Respiratory or skin sensitization Germ cell mutagenicity Carcinogenicity Reproductive toxicity Specific target organ toxicity - single/repeated exposure Aspiration hazard Aquatic toxicity- acute and chronic Hazardous to the ozone layer

Physical Hazards • • • • • • • • • • • • •

Explosives Flammable gases Flammable aerosols Oxidizing gases Gases under pressure Flammable liquids Flammable solids Self-reactive substances and mixtures Water reactive substances Oxidizing liquids Oxidizing solids Organic peroxides Corrosive to metals

Generating a Label and SDS • Gather all formula information, test results and physical data • For each health/environmental/physical hazard, use the data to classify • Once classified, standard warnings and precautions are required based on classification (little room for interpretation) • Create the label and SDS to include all the required information

What Do I Need to Do? • Classify products you manufacture • Develop SDSs and labels for these products • Train workers to understand the new pictograms and classifications

The Bad News is…. • …that classifying each substance or mixture is extremely complicated, time consuming and requires the help of a professional or computer software program AND • developing an SDS and a label is technically challenging and requires substantial experience and expertise

The Good News is…. • …that unless you are the manufacturer and are responsible for authoring the SDSs, you have no obligation to generate them, but you must still understand the information and train employees • Candles do not require a SDS under OHSA regulations as they are considered articles!

Employee Training Requirements Under Hazcom • Employees must be trained to read and understand labels and information presented on SDSs including the new pictograms • The new SDSs may contain new information not typically seen in the past • All MSDSs should be replaced by SDSs as they become available

TOXIC (Oral, Skin, Inhalation)

CORROSIVE TO SKIN/EYES AND METAL

HARMFUL (Oral, Skin, Inhalation, Eyes), SENSITIZER, TARGET ORGAN

CARCINOGEN, MUTAGEN, CHRONIC TOXIN, TARGET ORGAN, TOXIC TO REPRODUCTION

EXPLOSIVE

FLAMMABLE

COMPRESSED GAS

OXIDIZER

Aquatic/Environmental Toxicity

ACUTE ORAL TOXICITY CATEGORIES AND WARNINGS LD50

Category 1

Category 2

Category 3

Category 4

Category 5

5 < 50 mg/kg

50 < 300 mg/kg

300 < 2000 mg/kg

2000 < 5000 mg/kg

Pictogram

No symbol

Signal word

Danger

Danger

Danger

Warning

Warning

Hazard Statement

Fatal if swallowed

Fatal if swallowed

Toxic if swallowed

Harmful if swallowed

May be harmful if swallowed

New SDS Format 1. 2. 3. 4. 5. 6. 7. 8.

Identification Hazard(s) identification Composition/information on ingredients First-aid measures Fire-Fighting Accidental release measures Handling and storage Exposure control/personal protection

New SDS Format 9. 10. 11. 12. 13. 14. 15. 16.

Physical and chemical properties Stability and reactivity Toxicological information Ecological information ** Disposal considerations ** Transport information ** Regulatory information ** Other information

**OSHA will require, but not enforce these sections

WAX-AWAY Wax Remover DANGER: Flammable Liquid and Vapor. Toxic if Swallowed Keep away from heat/sparks/open flames/hot surfaces. Keep container tightly closed. Use explosion proof equipment. Wear protective gloves. Do not eat or drink when using this product. If swallowed immediately call a poison control center or doctor. If on skin remove contaminated clothing and rinse with water. In case of fire: use dry Chemical, CO2 or alcohol foam. Store locked up in a well ventilated place. Dispose in accordance with local regulations The Solvent Company 999 E. Flamingo Road Las Vegas, Nevada 89101 702-555-1212

Summary of Major Changes Under OSHA GHS • Material Safety Data Sheets (MSDS) will become Safety Data Sheets (SDS) • All SDS will have a specified 16 Section format • Signal words: Only WARNING and DANGER (No CAUTION) • New pictograms to learn • Standard hazard statements and symbols will be required on labels and SDSs based on classification

Time Line • OSHA to publish final rule soon (August 2011) • Employers must train workers under the new Hazcom regulations within 2 years of final rule publication • Full implementation within 3 years of final rule publication

QUESTIONS? Rob Harrington Blyth [email protected]