ghs: the new osha challenge presented at ul pure safety user group september 19, 2012

GHS: The New OSHA Challenge

Presented at UL Pure Safety User GroupSeptember 19, 2012

What is GHS?

Globally Harmonized System of Classification and Labeling of Chemicals

AKA OSHA 2012 Final rule published March 26, 2012 Effective date – May 25, 2012

History of GHS

1992 - Rio Conference 2002 – 1ST Purple Book Issued 2005 – OSHA announces decision to

adopt GHS principles 2006 – NPRM 2012 – OSHA issues revision to

Hazard Communication regulation

Other Agency Involvement

Department of Transportation Continues to harmonize regulations

with international regulations Environmental Protection Agency

Still evaluating GHS for pesticides Consumer Product Safety

Commission (CPSC) Nothing being done

Why is OSHA adopting GHS?

Common approach to classifying and communicating hazards

Improve quality and consistency of information

Harmonized definitions of hazards Specific requirements for labels Required format for SDS

Status of GHS Implementation

67 countries in have or are in the process of implementing GHS

Implemented or in EU – Full compliance 2015 Australia, New Zealand Japan China – Required 2011 Mexico, Brazil Canada – Not adopted yet

Major Changes

Hazard classification versus risk classification (no longer performance-oriented)

Labels – specific requirements including pictograms

16 Section SDS

Organization of the Final Rule

Purpose b) Scope and Application c) Definitions d) Hazard Classification e) Written Hazard Communication Program f) Labels and Other Forms of Warning g) Safety Data Sheets h) Employee Information and Training i) Trade Secrets j) Effective Dates Appendices A–F

APPENDICES

• Appendix A, Health Hazard Criteria (Mandatory) (NEW)

• Appendix B, Physical Hazard Criteria (Mandatory) (NEW)

• Appendix C, Allocation of Label Elements (Mandatory) (NEW)

• Appendix D, Safety Data Sheets (Mandatory) (NEW)

• Appendix E, Definition of “Trade Secret” (Mandatory)

• Appendix F, Guidance for Hazard Classifications

re: Carcinogenicity (Non-Mandatory) (NEW)

SOME NOTABLE CHANGES

OSHA 1994 Physical hazard – closed list Health hazard – open list

Defined as chemical causing acute or chronic health effects

OSHA 2012 Physical hazard – closed list Health hazard – closed list Adds combustible dust, simple asphyxiant,

pyrophoric gas and not else where classified

SOME NOTABLE CHANGES

OSHA 1994 Performance Oriented

Definitions Floor of chemicals considered hazardous One study rule

OSHA 2012 Specification based

Classification vs. determination Weight of evidence Detailed criteria for each hazard class

SOME NOTABLE CHANGES

OSHA 1994 Assigns chemical to a hazard class Nothing to show severity – reliance on

other labeling systems such as HMIS and NFPA

OSHA 2012 Assigns chemical to a hazard class

Hazard type Assigns chemical to hazard category

Degree of severity

SOME NOTABLE CHANGES

OSHA 1994 Physical Hazard

Flammable and combustible liquids Oxidizer

OSHA 2012 Physical hazard

Flammable Liquids 1, 2, 3, and 4 Oxidizing Gases 1, Oxidizing Liquids 1,2,

and 3, Oxidizing Solids 1, 2, 3

SOME NOTABLE CHANGES

OSHA 1994 Health Hazard

Highly toxic, toxic Corrosives Irritants

OSHA 2012 Health hazard

Acute toxicity 1, 2, 3, and 4 Skin Corrosion/Irritation 1a, 1b, 1c and 2 Serious eye damage/irritation 1 and 2

SOME NOTABLE CHANGES

Mixtures OSHA 1994 – Mixtures

Tested – Use data Untested – 1% for hazards except 0.1%

for carcinogens

SOME NOTABLE CHANGES

Mixtures OSHA 2012 –Tiered approach

Use test data if available Bridging principles Estimate hazards based on ingredient

information Specific requirements for each hazard

class Does not apply to carcinogens

Important Dates

December 1, 2013 – Employers must train employees on new label requirements, pictograms and new SDS format

June 1, 2015 – Chemical manufacturers, importers and distributors and employers must comply with all provisions

LABELS

REQUIRED INFORMATION

OSHA 1994 Identity of hazardous chemical Appropriate warnings Name and address of responsible party Label phrasing developed by

manufacturer

LABELS

REQUIRED INFORMATION OSHA 2012

Product Identifier Signal Word Hazard Statements Pictograms Precautionary statements Name and address of responsible party

LABELS

OSHA 2012 Mandatory phrasing Pictograms require a red border No blank boxes for pictograms Only Danger and Warning May have labels that do not contain a

signal word Manufacturer can include other

information such as PPE pictograms as well as use information

PICTOGRAMS

Examples of required phrase

Toxic Material Danger Fatal if Swallowed Required skull and crossbones pictograms Prevention – Wash thoroughly after handling.

Do not eat, drink or smoke when using this product

Response – If swallowed, Immediately call poison center/doctor…

Specific treatment – Rinse mouth Storage and disposal

(Material) Safety Data Sheets

Now called Safety Data Sheets Uses standardized 16 section OSHA includes Sections 12-15 but

will not enforce those sections Ecological information Transportation Disposal Regulatory Information

Safety Data Sheets

Sections 2 and 3 switched Required data within each section Can not leave anything blank – put in “no

information available”, “not applicable” or “not determined”

Still need to include ACGIH TLV and OSHA TWA values – Required for Section 8

Still need IARC and NTP Info in Section 11

Safety Data Sheets

Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.

Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.

Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.

Safety Data Sheets

Section 4, First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.

Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.

Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.

.

Safety Data Sheets

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; personal protective equipment (PPE).

Section 9, Physical and chemical properties lists the chemical's characteristics.

Safety Data Sheets

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; numerical measures of toxicity.

Section 12, Ecological information* Section 13, Disposal considerations* Section 14, Transport information* Section 15, Regulatory information* Section 16, Other information, includes the

date of preparation or last revision

Important Dates

Up to December 1, 2015 – Distributors may ship products previously labeled under old system

June 1, 2016 – Update alternative workplace alternative labeling and hazard communication programs and provide additional training to employees

Transition Period – Comply with OSHA 1994, OSHA 2012 or both

COMPLIANCE CHALLENGES

For Quaker 10,000 products will need classified

under the new system Need GHS classification for raw

materials Need GHS-compliant SDS information

from raw material suppliers Changes to labels and SDS Train employees on new labels,

pictograms and SDS format

COMPLIANCE CHALLENGES

For Employers Obtain new SDS from suppliers Train employees on new labels,

pictograms, SDS Update Hazard Communication

program Update alternative labeling systems if

being used Transition period with both systems will

create confusion in the workplace

Resources for Additional Information

United Nations http://www.unece.org/trans/danger/pub

li/ghs/ghs_welcome_e.html OSHA

http://www.osha.gov/dsg/hazcom/index.html

Copy of Federal Register http://www.osha.gov/dsg/hazcom/ghs-

final-rule.html

Contact Information

Kathryn F. Strang, CHMMSr. Advisor – Safety, Health and

Environmental 610-832-4304strangk@quakerchem.com