YOUR GHS PROGRAM: ARE YOU  READY FOR JUNE 1, 2016 October 27, 2015 3:00 – 4:00 p.m.

Discussion Objectives Background on the GHS and OSHA HazCom 2012 Implementation Timeline Remaining Requirements to be implemented OSHA Compliance Enforcement Directive Regulator’s Perspective on HazCom 2012 Industry Perspective on Implementation Challenges and Successes

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GHS Background What is the GHS? – It is the Globally Harmonized System of Classification and Labeling of Chemicals – It is a system used to standardize hazard communication in a global economy – The GHS defines health, physical and environmental hazards of chemicals implementing a classification process → Uses defined criteria →Communicates the hazard information →Communicates the protective measures on labels and safety data sheets

– The GHS was created and is revised by the United Nations

GHS Background Benefits of the GHS – Standardize chemical hazard communication in a global setting – Provide hazard communication framework for countries without a current system in place – Improve comprehension of hazards in the workplace

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GHS Background  Changes to OSHA’s Hazard Communication Standard (HCS) (29 CFR 1910.1200) – Final Rule published in the Federal Register on March 26, 2012 with an effective date of May 25, 2012 – The GHS is incorporated into the updated HazCom Standard which is referred to as HazCom 2012 – Chemicals and chemical mixtures are classified as health and/or physical hazards based on specific GHS criteria – Each classification correlates to a standard signal word, pictogram, hazard and precautionary phrases – Chemical manufacturers must classify their products based on evaluation of data and expert judgment – Schedule established for implementation of all aspects of the updated HCS

Who Is Impacted By HazCom 2012?  Manufacturers, Distributors, Importers – Provide product hazard information compliant with the GHS classification requirements – Includes Safety Data Sheets and Labels

 Employers – Train employees on changes in hazard communication information provided for chemicals used in the workplace – Ensure Safety Data Sheet and Label information is available to all employees

 Employees – Attend training – Recognize and understand chemical hazards in the workplace based on GHS classification

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Safety Data Sheets Material Safety Data Sheets (MSDSs) are referred to as Safety Data Sheets (SDSs) under HazCom 2012 HazCom 2012 SDSs must be prepared in a uniform 16‐ section format Recommended use of the chemical and any restrictions on use must be provided

Safety Data Sheets Section 2 of the SDS identifies product hazards and includes classification, pictograms, signal word, hazard statements, precautionary statements and a description of any hazard not otherwise classified (if applicable) Section 3 identifies exact percentages of classified chemical components unless the exact percent is a trade secret or there is batch‐to‐batch variability Physical and chemical properties to be included in Section 9 of the SDS are specified

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Labels GHS standard label components: – Symbols (hazard pictograms) which convey health, physical and environmental hazard information →Pictograms on shipped containers must have white background and red border →Blank diamonds (red borders with no symbol) are not allowed

– Signal words (either “Danger” or “Warning”) which are used to emphasize the relative degree of hazard – Hazard statements which are standard phrases describing the nature of the hazard – All of the above are assigned by GHS hazard class and category

Labels Additional required label components include: – Manufacturer contact  information – Product identifier – Precautionary statements

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Labels Previously labels were required to provide hazard information but the format was left to the discretion of the manufacturer All containers of GHS classified chemicals supplied to the workplace by manufacturers, importers and distributors must be properly labeled and the label must not be removed from the container while in the workplace

Labels  Workplace containers may be labeled using the GHS label format or using the product identifier and words, pictures, symbols or some combination of these as long as the health and physical hazards are properly conveyed. Employers continue to be able to use signs, placards, batch tickets or similar written materials to identify hazards in stationary process vessels.  Portable containers do not have to be labeled when they are intended for immediate use by the employee who transferred the hazardous chemical from a labeled container

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Timing Effective Completion  Dates

Requirement

Who

Dec. 1, 2013

Train employees on the new label elements and SDS  Employers format

Jun 1, 2015

Compliance with all modified provisions of the final  rule

Dec 1, 2015

The distributor must not ship containers labeled by  the chemical manufacturer or importer unless it is a  Distributors Hazard Communication standard (HCS) 2012 label

Jun 1, 2016

Update alternative workplace labeling and hazard communication program as necessary, and provide  additional employee training for newly identified  physical or health hazards

Chemical manufacturers,  importers, distributors and  employers

Employers

Remaining Requirements  Manufacturers, Importers and Distributors – SDSs should meet HazCom 2012 requirements as of June 1,  2015 – Manufacturers and importers must meet labeling requirements as of June 1, 2015 – Distributors have until December 1, 2015 to comply with labeling requirements, unless they are repackaging and relabeling and/or creating SDSs; in that case the June 1, 2015 compliance date is applicable – In cases where product was packaged and labeled prior to June 1, 2015 using HCS 1994‐compliant labels but shipped after June 1, 2015 manufacturers must provide HCS 2012‐compliant labels for each individual container shipped

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Remaining Requirements Labels – All containers in the control of a distributor after December 1, 2017 must be labeled with HCS 2012‐ compliant labels prior to shipping – If unable to classify chemical mixtures due to lack of classification information from upstream suppliers, documentation must be maintained to demonstrate efforts to obtain information either from supplier or alternative sources →Once SDS is created, HazCom 2012 labels must be created within six (6) months

Remaining Requirements Employers – Continue to maintain all SDSs received from suppliers – Review hazards as determined by GHS criteria in SDSs and update employee training when warranted to convey these hazards – Update written program to incorporate changes in training and workplace labeling no later than June 1, 2016

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Remaining Requirements Employers ‐ continued – Ensure workplace labeling program properly conveys all identified physical and health hazards →Pictograms are not required but if used, a black border is acceptable →Precautionary and hazard statements may be used but are not required →Rating systems such as HMIS or NFPA may be used as part of the workplace labeling system as long as the information is not contradictory to other labeling on the container and employee is able to determine applicable physical and health hazards; words, pictures and/or symbols may be used in conjunction with a rating system to convey all hazards

OSHA’s HazCom 2012 Enforcement Directive  Effective date July 9, 2015  Used to ensure uniform enforcement of the HCS  Reasonable Diligence and Good Faith Efforts – Obtain classification information and SDSs from upstream suppliers – Find hazard information from alternative sources (e.g. chemical registries) – Classify data on your own – Documentation must be maintained to demonstrate efforts →Continued contact with upstream suppliers →Alternative source search →Course of action once hazard information is obtained

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Regulator’s Perspective Objective is safety of employees Employees must have unrestricted access to SDSs Employee training is required at the time an employee is required to work with a hazardous chemical and whenever a new hazard is introduced into the work area Temporary employees must be trained to the same level as full time employees performing the same work

Industrial Perspective Training – Deadlines for the completion of training and plant implementation far apart →Requires training on both the old and new HCS →Will need to increase the frequency of awareness/refresher training after implementation to ensure all employees are fully understanding the GHS methodology

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Industrial Perspective Supplier Compliance – What do you do if a supplier has not complied with the December 1, 2015 deadline? →Instructed our plants to not accept the shipment…this is easier said than done though →So, we will have to provide the proper labeling on their containers when it comes into our building →Major Problem: Many of our locations receive chemicals directly from Japan because they are called out as “print chemicals”

Industrial Perspective Aisin as a supplier: – Our major customer required that we change over to the SDS format ahead of the OSHA deadline →This caused our location to rush analysis on the chemical to be able to classify it under the new requirements…thus costing more $$ →Our Japan location was involved in the testing so it made the rush even more difficult →Received help from our consultants…which costs $$

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Industrial Perspective Employee Access to SDSs: – Most of the locations utilize an electronic SDS system which is web based – Additional steps in the plants →If you only have room for pictograms, or other identification means (e.g. Red Dot), then you have to make the complete label information available in the work area – This would force us to make a communication board in the areas just for chemicals – Not too terrible, but just one more thing you have to make sure is updated continuously

Industrial Perspective  Labeling – The labeling requirements are obviously more in depth and contain a lot of information →This makes it difficult when labeling secondary containers

– In the old system, you could hand write numbers in a box with the name and call it a day…NOW you must have all the GHS information on the label or accessible in the work area – In the past you could stock an area with the HMIS or NFPA labels and a Sharpie, to create replacement labels in no time – Now…have to come up with a fail proof system (probably through trial and error) for in plant labeling →Hopefully, the wonderful folks at IOSHA are not the ones that find the Error!

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Industrial Perspective Labeling ‐ continued – Due to the different sizes and environments at our North America location, it has been proven difficult to create a corporate system for labeling →Basically, we will audit our locations to ensure the way they choose to label is compliant with the new HCS

Conclusion Compliance with HCS 2012 is critical for your business to ensure employee safety in the workplace – Authoring, distributing and maintaining SDSs – Use of compliant, effective labeling – Training of employees to identify chemical hazard risks in the workplace and how to protect themselves – Updating written program to reflect changes in training, hazard identification, labeling – Reasonable Diligence and Good Faith Efforts to ensure hazard classification information is being provided to employees

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Contact Information Pamela Dickerson,  CHMM Cornerstone,  Environmental, Health  and Safety, Inc.

Mark Warren Manager – Safety /  Environmental AISIN WORLD CORP.  OF AMERICA

Bradley Freeman,  CIH, CSP INSafe Health  Consultant Indiana Department  of Labor

317‐733‐2637

812‐524‐8144  Ext 43137

317‐232‐2655

pdickerson@corner‐ enviro.com

mwarren@aisinworld .com

[email protected]

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