Globally Harmonized System The content of this document is general in nature and provided to you for informational purposes only. The information is derived from sources believed to be reliable and is offered as a resource to be used together with guidance from your professional insurance, legal, and safety advisors in maintaining a loss prevention program. ACUITY assumes no liability by reason of the information contained in this document. If you have a specific concern you should contact your professional insurance, legal, or safety advisors.
Senior Loss Control Representative
OSHA revised the Hazard Communication Standard effective May 25, 2012.
This affects any employer who maintains MSDSs on chemicals in the workplace.
The primary reason for the revision is the Globally Harmonized System (GHS).
November 25, 1985 - Effective date for the manufacturing sector
September 23, 1987 - Expanded to cover all nonmanufacturing employees
February 9, 1994 - Final Rule with minor modifications
Hazard communication, also known as HazCom, is the “RIGHT TO KNOW.”
This program is not intended to tell you how to do your jobs
It is not a technical chemical safety course.
Leading Violations Hazard Communication - Written program 1925
1200(e)(1)
Hazard Communication - Training initially and for new hazards 953
1200(h)(1)
Hazard Communication - Information and training 770
1200(h)
Hazard Communication - MSDS 662
1200(g)(1)
Hazard Communication - Label identification 398
1200(f)(5)(i)
An approach to defining and classifying hazards for chemicals, including pesticides.
Labels and MSDSs will be changed.
Affected parties: chemical companies, consumers, pesticide applicators and workers, transport workers, and emergency responders.
Why Is the GHS Important?
Principles of the Harmonization Process o o
o o o o
Protection will not be reduced Will be based on intrinsic properties (hazards) of chemicals All types of chemicals will be covered All systems will have to be changed Involvement of all stakeholders should be ensured Comprehensibility must be addressed
Regulation 29 CFR 1910.1200 o
12/1/2013 Train ALL Employees On New Label Elements and Safety Data Sheet (SDS) Format • There is no “standard” training, just so employees understand
o
o
o
6/1/2015 All Manufactures Must Comply With Provisions 12/1/2015 Distributors Must Comply With Provisions 6/1/2016 Employers Update HazCom Program, Alternative Labeling, and Newly Identified Hazards • All paperwork must be updated by this date
Employees must be informed of: o o
o
o
Requirements of the HazCom Standard. Location of hazardous chemicals in their work area and chemical list. Location and availability of the written hazard communication program. Location and availability of MSDSs.
Who - each employee who may be “exposed” to hazardous chemicals
When - prior to initial assignment to work with hazardous chemicals and whenever the hazard changes or a new hazard is introduced
Method - performance oriented (lecture, interactive, or videotape) o o
Individual chemicals Categories of hazards (e.g., corrosives)
“Hazardous Chemical” o
“Exposure” o
Any chemical which is a physical or health hazard
Any employee is subjected in the course of employment to a chemical that is a physical or health hazard and includes potential (e.g., accidental or possible) exposure
“Subjected” o
Any route of entry, inhalation, ingestion, skin, or absorption
Chemical manufacturers and importers are responsible for evaluating the hazards of the chemicals they produce
Employers may rely on these hazard evaluations
Appendix A (Health Hazard Definitions)
Appendix B (Hazard Determination)
Must be trained on the methods and observations used to detect the presence or release of hazardous chemicals in their work area o o o
Physical and health hazards of chemicals Air monitoring or continuous monitoring devices Visual appearance or odors of hazardous chemicals (some have no odor, little odor, or may cause olfactory fatigue)
Methods to prevent or minimize exposures/protect themselves o o
o o o
Substitution – use of less hazardous chemicals Engineering Controls – ventilation, isolation Safe Work Practices Administrative Controls – training Use of Personal Protective Equipment
Defined criteria are used to assign a hazard classification o
Physical Hazards • 16 categories
o
Health Hazards • 10 categories
o
Mixtures • GHS classification guidance for when chemicals are mixed
Physical Hazards (16 categories) Explosives
Pyrophoric Liquids
Flammable Gases
Pyrophoric Solids
Flammable Aerosols
Self-Heating Substances
Oxidizing Gases
Substances Which, in Contact With Water, Emit Flammable Gases
Gases Under Pressure
Oxidizing Liquids
Flammable Liquids
Oxidizing Solids
Flammable Solids
Organic Peroxides
Self-Reactive Substances
Corrosive to Metals
Health Hazards (10 categories) Acute Toxicity
Reproductive Toxicity
Skin Corrosion/Irritation
Target Organ Systemic Toxicity – Single Exposure
Serious Eye Damage/Eye Irritation
Target Organ Systemic Toxicity – Repeated Exposure
Respiratory or Skin Sensitization
Aspiration Toxicity
Germ Cell Mutagenicity
Carcinogenicity
Only two signal words used (some will have none) o o
Danger – with skull and crossbones Warning
Cut-off points are changed for signal words and other categories for determining precautionary statements
Additional hazard statements for aquatic hazard
Use of pictograms
GHS Label Example
Product identifier
Supplier identifier
Chemical identity
Hazard pictograms (standardized)
Signal words (standardized)
Hazard statements (standardized)
Precautionary information
GHS Pictograms o
A single harmonized hazard statement for each level of hazard within each hazard class o
Example: Flammable Liquids • • • •
Category 1: Extremely flammable liquid and vapor Category 2: Highly flammable liquid and vapor Category 3: Flammable liquid and vapor Category 4: Combustible liquid
Transport Pictograms – DOT Regulated
NFPA Label
HMIS Label
Current Requirements o
o o o
Must be readily accessible to employees in their work areas during their work shifts. Employees must have access. Access may be computerized (electronic access). If employees travel between worksites, MSDS must be at the primary worksite.
1. Identification 2. Hazard(s) identification
3. Composition/information on ingredients
9.
Physical and chemical properties
10. Stability and reactivity 11. Toxicological information
4. First-aid measures
12. Ecological information
5. Fire-fighting measures
13. Disposal considerations
6. Accidental release measures
14. Transport information
7. Handling and storage
15. Regulatory information
8. Exposure control/personal protection
16. Other information
GHS Websites o
o o o
Government Printing Office o
OHSA – http://www.osha.gov/dsg/hazcom/global/html EPA – http://www.epa.gov/oppfead1/international/globalharmon.htm DOT – http://www.phmsa.gov/phth/GHSpolicy.html UN – http://www.unece.org/trans/danger/publi/ghs_rev02/02file Federal Digital System – http://www.gpo.gov/fdsys/
OSHA Comments o
Docket No. OSHA-H022K-2006-0062 at http://www.regulations.gov
o
Over 650 items!
For further assistance o o
o
Call your Agent Contact ACUITY Loss Control at 800.242.7666 Send an email to
[email protected]
“Like” us on Facebook
Visit www.ACUITY.com