This training session is designed to provide information to employees who work with

1 This training session is designed to provide information to employees who work with hazardous chemicals and substances. Employers are required to ...
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This training session is designed to provide information to employees who work with hazardous chemicals and substances. Employers are required to provide training to employees by December 1, 2013. The emphasis here is on changes made to Hazard Communication training due to the requirements associated with Global Harmonization.

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This training includes: • An overview of the changes to the OSHA HazCom Standard. • The new labeling requirements brought about by GHS. • Information on the new Safety Data Sheets in the 16-section format. • Tips for employees to follow when using chemicals. • Details of the facility-specific HazCom program. The information on facility-specific training is designed to provide guidance to employers on information they must include in order for the employee training program to be compliant with the OSHA HazCom Standard.

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Why the change? Since 1992, the United Nations has been working to create and enhance a globally harmonized system for the classification and labeling of chemicals that can be used by importers, distributors, and manufacturers worldwide. The goal is to provide a common approach worldwide to classifying chemicals. This will benefit employees as it will: • Reduce confusion and increase understanding of the hazards. • Make training easier. • Help address literacy problems by the use of pictograms.

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There are three main groups affected by the changes that are being made. Workers need to concentrate on recognizing the changes being made to the old MSDS format and understanding the pictograms and hazard statements that will be on chemical container labels.

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Here is a list of the other OSHA standards that are affected by the HazCom/GHS changes. Language on required signs in these standards will be harmonized with HazCom and GHS. For example, the sign for lead will be changed as noted above. You will be specifically trained regarding any of the above if they are present in your workplace.

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This is a listing of the other standards affected. In some cases, definitions may have changed in the standards list above. Again, you will be specifically trained about these changes if they apply to your work situation.

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In the past, chemical hazards were evaluated in a more subjective manner. Chemicals must now go through a specific classification process to determine which hazards are present and which hazard and precautionary statements apply. This is often a lengthy process. Environmental Hazards are not regulated by OSHA and will not be covered in this presentation.

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Now there are 11 established chemical health classifications. These are further defined and described in the HazCom Standard. Note: Simple Asphyxiants are not part of the current international GHS standard but were specifically included by OSHA as a hazard classification under the 2012 HazCom Standard.

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This chart shows the new health hazard classes and the hazard categories that correspond to each of the health hazard classes. Hazard category 1 (or column furthest to the left) is the most hazardous. Hazard categories become less severe as you move to the right in the chart. In other words, this is the opposite of the current system. The higher numbers represent less hazard. Manufacturers, importers, and distributors must classify all hazards for their products.

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Each of the chemical physical classifications are further defined and described in the HazCom Standard. Manufacturers, importers, and distributors must determine if any of their products are classified as a physical hazard. If the product is classified as a physical hazard in one or more of the physical hazard classifications, a formalized system is used to determine the severity of the hazard (or hazard category).

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Note that Pyrophoric Gases are not part of the GHS (international standard) but were specifically included by OSHA as physical hazard classifications under the 2012 HazCom Standard. Pyrophoric means capable of self-igniting in air.

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Note that Combustible Dusts are not part of the GHS (international standard) but were specifically included by OSHA as physical hazard classifications under the 2012 HazCom Standard.

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This chart shows the physical hazard classes and the hazard categories that correspond to each of the physical hazard classes. Hazard category 1 (or column furthest to the left) is the most hazardous. Hazard categories become less severe as you move to the right in the chart. This numbering system is the opposite of what you are familiar with. In other words, the higher the number, the lower the potential problem. Manufacturers, importers, and distributors must classify all hazards for their products.

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This is an example of the new label style that is to appear on product labels beginning no later than June 1, 2015 (or December 1, 2015, for distributors who still have product in inventory after the June deadline). The type of required information is noted in blue. Match up the blue wording listed on the left-hand side of the page with corresponding blue wording on the sample label. Note what the pictograms and cautionary wording might look like. The actual statements and information will vary depending on the specific health and physical classification of the product. More information on the makeup of these labels will be presented shortly.

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Note the difference in the shipping label compared to the container label on the previous slide. Department of Transportation (DOT) requires that additional information be noted on shipping containers. See bottom right corner of the label for shipping pictogram. Even though you may seldom or never work directly with shipping containers, OSHA requires that employees be knowledgeable of both the container and shipping labels. As is the case with this label, generally the primary difference is in the placement of the information on the labels.

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Here is a guide to GHS Transport Pictograms from the OSHA website: http://www.osha.gov These are DOT labels and may appear on transport containers depending on the classification of the chemical. You may or may not be exposed to containers with these labels in the course of your work. If you do work with containers, your employer is required to specifically train you on shipping container labels you may encounter on the job.

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There are nine OSHA-related pictograms in all. The first three pictograms are specific to health hazards. They are exclamation, health hazard (silhouette of a person with starburst on the chest), and skull and crossbones. The fourth pictogram can represent both a physical and/or health hazard of corrosives. The last four pictograms are specific to physical hazards. They are exploding bomb, flame, flame over circle (oxidizer), and gas cylinder. The middle pictogram is for environmental hazards. Environmental hazards are not regulated by OSHA. The following four slides will provide more detail related to the pictograms.

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These two pictograms relate to acute toxicity (short-term exposure). The skull and crossbones is for any substance that is classified as having acute toxicity in health hazard categories 1-3. The acute toxicity health class category 4 (least hazardous) is represented by an exclamation mark. These two pictograms will never appear on the same label. It will be one or the other with skull and crossbones representing the more severe hazard. Additional information for labeling and language associated with these pictograms is found in Appendix C of the HazCom Standard.

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Many of you are familiar with the pictogram for corrosion on the left. This is the only pictogram that can represent both a health and a physical hazard. The pictogram on the right is called the “health hazard” pictogram. It is represented by the silhouette of a person with a starburst across the chest. This is used to indicate that the substance is a chronic (long-term exposure) and/or target organ hazard.

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The next two slides (five pictograms) represent physical hazards.

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Note that the corrosive pictogram used to designate corrosion to metal is the same pictogram used for skin corrosion/serious eye damage/eye irritation under the health hazard classification. This symbol can be used for both health and physical hazards. Not all health hazards represented by this pictogram are corrosive to metal, so it is important to look for additional information on the label and in the SDS. Oxidizers are chemicals that can emit oxygen and increase the risk of fire. If you are ever unsure of the meaning or importance of a pictogram you see on a label, talk to your supervisor to be sure you are handling that chemical correctly.

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Previously, there may have been several signal words used to indicate a hazard like caution, warning, or danger. The GHS permits the use of only two signal words: “Danger” and “Warning.” Only one of the signal words is permitted to appear on the label based on the classification of the chemical. Remember that the word “DANGER” represents a more severe hazard than the word “WARNING.”

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Definition of hazard statement: "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. Manufacturers, importers, and distributors use the classification system outlined in GHS to identify which statements must appear in the SDS.

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Definition of precautionary statement: "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. The employer is to evaluate the precautionary statements to determine if these need to be followed by employees. This decision may be based on several factors such as the following: • How the chemical is used • Where it is used (ventilation concerns) • How much of the chemical is used (quantity) • The results of air sampling or testing (permissible exposure limits) • How long the chemical is in use (time) • Other considerations As an example, a precautionary statement may state “Wear respiratory protection.” However, employees may not be required to wear a respirator based on the employer’s evaluation of the factors listed above (how, where, how much, time, PEL).

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Definition of product identifier: "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.

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This is optional information that may be provided by the manufacturer, importer, or distributor. This information is not required to be on the label; however, it will be found in the SDS.

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This slide identifies each of the six required sections/elements of the new label in addition to a section on Supplemental Information (this section is not required to be on each label). These seven sections are outlined in green and include: •Pictograms •Product identifier •Signal word •Hazard statements •Precautionary statements •Supplier identification •Supplemental information Please take some time to familiarize yourself with the terminology and where you might find the information on a typical label such as this.

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HMIS = Hazardous Materials Information System (National Paint and Coatings Association) NFPA = National Fire Protection Association GHS vs. HMIS/NFPA 704 In the NFPA and HMIS systems, number “4” indicates a severe hazard. Under GHS and the HazCom Standard, when a manufacturer, importer, or distributor classifies a chemical a category “4” it is the least severe and category “1” is the most severe. Please note that the new GHS numbering system is very different from the numbering system used by NFPA and HMIS. Make sure that you are properly trained and understand the specific potential hazards of all chemicals you are required to use in your job. Whenever you have even a bit of doubt, ask your supervisor for guidance. GHS hazard category numbers may be noted in SDS; however, they are NOT required to be present on the container label.

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Manufacturers, importers, and distributors may begin using the new 16-section format SDS during the transition from the 1994 HazCom Standard and the final 2012 HazCom Standard but must switch no later than June 1, 2015. They are required to provide a revised copy of the MSDS/SDS to the employer anytime changes are made. Employers are required to maintain copies of all SDSs for the chemicals used and/or stored within the work area. They should have a system to ensure all SDSs are present/accounted for and to periodically check for the most current SDS (usually based on revision date) when received from a manufacturer, importer, or distributor. The employer is to maintain a copy of the most current SDS and archive prior MSDSs/SDSs. SDSs are to be accessible/available to employees.

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Section 1, Identification, includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; and restrictions on use. Section 2, Hazard(s) identification, includes all hazards regarding the chemical and required label elements. Section 3, Composition/information on Ingredients, includes information on chemical ingredients and trade secret claims. Section 4, First-aid measures, includes important symptoms/effects (acute and delayed) and required treatment. Section 5, Fire-fighting measures, lists suitable extinguishing techniques, equipment and chemical hazards from fire. Section 6, Accidental release measures, lists emergency procedures, protective equipment, and proper methods of containment and cleanup.

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Section 7, Handling and storage, lists precautions for safe handling and storage, including incompatibilities. Section 8, Exposure controls/personal protection, lists OSHA's Permissible Exposure Limits (PELs), Threshold Limit Values (TLVs), appropriate engineering controls, and personal protective equipment (PPE). Section 9, Physical and chemical properties, lists the chemical's characteristics. Section 10, Stability and reactivity, lists chemical stability and possibility of hazardous reactions. Section 11, Toxicological information, includes routes of exposure, related symptoms, acute and chronic effects and numerical measures of toxicity.

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Sections 12-15 are not regulated by OSHA. Section 16, Other information, includes the date of preparation or last revision. *Note: Since other agencies regulate this information, OSHA will not be enforcing Sections 12 through 15.

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Employers must provide facility-specific instruction to employees as described on this slide and the next slide to be compliant with the HazCom training requirements. This means your employer must train you in the specific chemicals which you will be exposed to in your job. Employers must also maintain and periodically review the written HazCom program for the facility which contains all of the information on this slide and the next.

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NOTE: Training does not meet the requirements of the HazCom Standard if the employer fails to provide facility-specific instruction to employees on the following: •Location and availability of written program and SDSs •Physical hazards, health hazards, and hazards not otherwise classified (HNOC) of the chemicals in the work area •Chemical list, location, and use of hazardous chemicals •Secondary container labeling system •Specific procedures to protect employees from the chemical hazards •Methods used to detect the presence or release of the hazardous chemicals (sensor alarms, odors, visual, and other monitoring devices)

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The tips on the next few pages are some common sense precautions to take when handling all chemicals.

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Mixing chemicals can often cause dangerous reactions. Unless you have been specifically trained in the proper procedures, never mix chemicals.

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This slide highlights some of the additional resources available on the Federal OSHA website. OSHA HazCom Web Page: www.osha.gov/dsg/hazcom/index.html OSHA Guide to GHS: www.osha.gov/dsg/hazcom/ghs.html

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Here’s a summary of items covered in this presentation. If you are unclear on any of the concepts, please review the information again, or contact your supervisor.

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