the risk management solution for local government globally harmonized system/ hazard communication...

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Globally Harmonized System/Hazard Communication

(Right-To-Know)CFR 1910.1200

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Why Did OSHA Align the HCS with GHS?

• A common coherent approach to classifying and communicating chemical hazards.

– Harmonized definitions of hazards

– Specific criteria for labels

– Harmonized format for safety data

sheets

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Benefits of Adopting the GHS

• Increase the quality and consistency of information provided to the workers, employers and chemical users.

– Reduce confusion/increase comprehension

of hazards

– Improve downstream risk management

– Facilitate training

– Help address literacy problems

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4

The Old System

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5

The New System

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A Brief History of GHS: It is not a new idea

•It was first discussed in 1983

•It was hoped that a global harmonized system (GHS) would be in place by 2000

•However it was not until 2005 that OSHA finally agreed to modify the HCS (Hazard Communication Standard) to add the adoption of GHS. 

•In 2009 OSHA asked for input from any and all interested parties 

•August of 2011 OSHA postponed release of final documents 

•Sept of 2011 OSHA issued final recommendations and guidelines for implementation, with a three year window for companies to implement the GHS in their HCS programs 

•2012 begins the three year timeframe to begin implementation of GHS 

•2015 the date by which all chemical companies should have switched over product labeling and labeling on items transported to GHS 

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Scenario

You are unloading three chemical containers from three different manufacturers. The containers all give various warnings regarding the chemical inside:

#1 “flammable”#2 “very flammable”#3 “highly flammable”

Which chemical container is most dangerous?

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Answer

They are all the same chemical,

and thus one container’s

contents are no more dangerous

than the others despite what

confusion the labels may create.

This is the reason for transitioning to GHS.

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Effective Dates

12/1/13: All employees must be trained on new label elements and SDS format

6/1/15: Manufacturers and distributors must comply with all modified provisions except that distributors have until 12/1/15 to provide revised labels for all products shipped.

6/1/16: OSHA enforcement starts: Employers must update all labels and Haz Com program, provide additional training for workers on newly identified physical or health hazards

Note: During transition period, employers can comply with old or new standard as far as labels and SDSs.

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Employee Training

• Provide information and train prior to initial assignment to work with a hazardous chemical

• Do initially, periodically, and whenever the hazard changes

• Must occur within 30 days of employment for new employees, full or part time

• Must be documented with detailed records of training maintained by the entity and available for review by supervisor, Safety Officer or training staff

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Training shall include:

Explanation of Hazard Communication ProgramExplanation of SDSs and how to access an SDSReview of chemicals used on siteReview of work area locations using hazardous

productsIdentification of hazards associated with the use

of chemicalsReview of protective measures required for

specific hazardsExplanation of the labeling system

Employee Trainingcontinued

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Notable Changes to Standard

• Using a “specification” approach rather than a “performance-oriented” approach– “Hazard classification” rather than

“hazard determination”• Labels are more defined• “Safety data sheet” (rather than material

safety data sheet) uses a 16 section format

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OSHA Standard(Also known as “Right to Know”)

5 Steps to Compliance

1. Develop a written Hazard Communication plan.

2. Inventory all hazardous chemicals.

3. Establish and maintain a complete library of Safety Data Sheets (SDS).

4. Label all containers, pipes and tanks.

5. Provide equipment and train your workforce.

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Contents of the OSHA Standard(Exemption)

The HCS does not apply to consumer products when used in the workplace in the same manner and with the same duration and frequency that a normal household consumer would use them at home.

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Labeling According to GHS

Information required on a GHS label:1. Product identifier2. Supplier identification3. Signal word4. Hazard statement5. Pictogram6. Precautionary statementOptional: Supplemental info

Labels must be affixed to, printed on or attached to each chemical container in the workplace.

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Labeling According to GHS - Workplace

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Labeling According to GHS - Transport

Effective June 1, 2015 all shipping labels will be required to have all GHS label elements

DOT Shipping

Flammable liquids, toxic, n.o.s.

(contains XYZ)UN 1992

Shipping Container Label (55 gallon/200 liter drum)

Pictograms within DOT label

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Labeling of Secondary Containers

If hazardous chemicals are transferred into unmarked containers:• label container with the required

information (GHS label elements)unless the container is intended for

immediate use by employee who performed the transfer (use portable container labeling guidelines)

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Labeling of Portable Containers

Employer is NOT required to label portable containers which are intended only for the immediate use of the employee who performs the transfer…

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Updating Labels

Labels and SDS’s should be updated within 6 months when new and significant information is available for a chemical.

“New and significant information” means any information that changes GHS classification and leads to a change in the information to be provided in the label or in the SDS.

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Product Identifier

Definition:Unique name or number used

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Supplier Identification

Definition:name, address and telephone

number of the manufacturer or supplier of the substance/mixture

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Signal Words

Definition:word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label

“Danger” (for more severe hazard categories)

“Warning” (for less severe hazard categories)*Only one of these words will be present on a label.

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Hazard Statement

Definition:phrase assigned that describes the nature of the chemical hazard, including where and the degree of hazard

Example statements are:- “Highly flammable liquid and vapor”- “Toxic if swallowed”- “Causes severe skin burns and eye damage”

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Pictograms

Definition:graphical composition that includes a symbol and other graphic elements, such as a border, background pattern or color that is intended to convey specific information

Transport Pictograms

Flammable Liquid Flammable Gas Flammable Aerosol

Flammable solid Self-Reactive Substances

Pyrophorics (Spontaneously Combustible) Self-Heating

Substances

Substances, which in contact with water, emit flammable gases

(Dangerous When Wet)

Oxidizing Gases Oxidizing Liquids Oxidizing Solids

Explosive Divisions 1.1, 1.2, 1.3

Explosive Division 1.4 Explosive Division 1.5 Explosive Division 1.6

Compressed Gases Acute Toxicity (Poison): Oral, Dermal, Inhalation

Corrosive

Marine Pollutant Organic Peroxides

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New Workplace Pictograms

Characteristics:- Shape: square set at a point.

Colors:- Background: white- Border: red- Symbol: black

GHS pictogram for skin irritant

!

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HCS Pictograms and Hazards

Health Hazard

Flame

Exclamation Mark

Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity

Flammables Pyrophorics Self-Heating Emits Flammable Gas Self-Reactives Organic Peroxides

Irritant (skin and eye) Skin Sensitizer Acute Toxicity (harmful) Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer

(Non Mandatory)

Gas Cylinder

Corrosion

Exploding Bomb

Gases under Pressure

Skin Corrosion/ burns Eye Damage Corrosive to Metals

Explosives Self-Reactives Organic Peroxides

Flame over Circle

Environment (Non Mandatory)

Skull and Crossbones

Oxidizers

Aquatic Toxicity Acute Toxicity (fatal or toxic)

(pg. 59)

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Which Pictogram Am I ?(Exercise Follows)

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CORROSIVES?

1.

2. 3. 4.

5.

6.

7.8.9.

Which Pictogram is

YES

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OXIDIZERS?

1.

2. 3. 4.

5.

6.

7.8.9.

Which Pictogram is

YES

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EMITS FLAMMABLE GAS?

1.

2. 3. 4.

5.

6.

7.8.9.

Which Pictogram

YES

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ACUTE/SEVERE TOXICITY?

1.

2. 3. 4.

5.

6.

7.8.9.

Which Pictogram is

YES

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RESPIRATORY SENSITIZER?

1.

2. 3. 4.

5.

6.

7.8.9.

Which Pictogram is

YES

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GASES UNDER PRESSURE?

1.

2. 3. 4.

5.

6.

7.8.9.

Which Pictogram is

YES

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Precautionary Statement

Definition:phrases that describe recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or from improper storage or handling of a hazardous product

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4 types of precautionary statements:

• Prevention (keep you from harm)

• Response (steps to take if you have been exposed)

• Storage (safe way to store)

• Disposal (how to dispose of safely)

Precautionary Statementcontinued

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Is it a Precautionary or a Hazard Statement?

• Keep away from heat/sparks/open flames/ hot surfaces

• Self-heating in large quantities; may catch fire

• Store in a well-ventilated place• Wear suitable protective clothing• Danger of serious damage to health by

prolonged exposure

PS

HS

PS

PS

HS

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Supplementary Information

• May include information such as:– PPE requirements for emergency

response– Expiration/Fill dates– Directions for Use– Referrals to other sources of

information

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Sample Workplace Label Example GHS Inner Container Label (e.g., bottle inside a shipping box)

ToxiFlam (Contains: XYZ)   

Danger! Toxic If Swallowed, Flammable Liquid and Vapor

Do not eat, drink or use tobacco when using this product. Wash hands thoroughly after handling. Keep container tightly closed. Keep away from

heat/sparks/open flame. - No smoking. Wear protective gloves and eye/face protection. Ground container and receiving equipment. Use explosion-proof

electrical equipment. Take precautionary measures against static discharge. Use only non-sparking tools. Store in cool/well-ventilated place.

 IF SWALLOWED: Immediately call a POISON CONTROL CENTER or

doctor/physician. Rinse mouth.

In case of fire, use water fog, dry chemical, CO2, or "alcohol" foam.

See Safety Data Sheet for further details regarding safe use of this product.

MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999

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Sample: Workplace Label 2

• Refer to handout of OXI252

• Note the pictograms

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GHS vs. HMIS vs. NFPA Labeling

Numbering reflecting severity: GHS numbering system is completely opposite HMIS or NFPA labels. Neither of these systems will meet the new labeling requirements of the GHS!        

       GHS Label                                   NFPA

label                                    HMIS Label

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Example: A 1 in our current labeling system means slight hazard, whereas the 1 in the GHS system means high danger : warning of a serious hazard.

Flammability Criteria

 GHS Category

 NFPA Rating

 HMIS III Rating

Flash point < 73°F(23°C) and initial boiling

point <100°F(37.8°C)

1 or 2 4 4

Flash point > 200°F(93.4°C)

and will burn in air when exposed to a temperature

of 1500°F(815.5°C) for a period of 5

min. (Slight hazard)

None 1 1

*Note:GHS number/hazard category

will not appear on labels, only in the SDS.

(Serious hazard)

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2012 ERG pdf and/or mobile apphttp://www.phmsa.dot.gov/hazmat/library/erg

Dangerous Goods Manual mobile app-GHS workplace pictograms      

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Location

Where is your SDS book located?

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Safety Data Sheets(pg. 58)

16-section detailed information bulletin

– Employer will have one for each hazardous chemical used in order

to develop worker protection measures

– SDSs must be updated by chemical manufacturer within 6 months

of new/significant information– SDSs are to be accessible to all employees

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Contents of SDS

• Section 1- Chemical Product and Company Identification

• Section 2-Hazard Identification (organized by routes of entry)

• Section 3- Composition, Information or Hazardous Ingredients

• Section 4- First Aid Measures (organized by routes of entry)

• Section 5- Fire and Explosion Hazard

• Section 6- Accidental Release Measures

• Section 7- Handling and Storage

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Contents of SDScontinued

• Section 8- Exposure Controls and PPE

• Section 9- Physical & Chemical characteristics

• Section 10- Stability and Reactivity Data

• Section 11- Toxicological Information

• Section 12- Ecological Information

• Section 13- Disposal Considerations

• Section 14- Transport Information

• Section 15- Regulatory Information

• Section 16- Other Information

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Getting to Know the SDS

You notice a strange odor when working with a new chemical. What section of the SDS will provide information about the odor?

• Section 9- Physical & Chemical characteristics

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Getting to Know the SDS

You develop a skin rash while working with a chemical. What section of the SDS will tell you about the effects of over exposure?

Section 8- Exposure Controls and PPE

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Getting to Know the SDS

What section describes safe work practices for chemical products ?

Section 7- Handling and Storage&

Section 8- Exposure Controls and PPE

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What is a hazardous chemical?

“Hazardous chemical means any chemical which is a

Physical , Health or Environmental hazard.”

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GHS Physical Hazards16 different physical hazard

classifications

– Explosives– Flammable Gases– Flammable Aerosols– Oxidizing Gases– Gases Under

Pressure– Flammable Liquids– Flammable Solids– Self-Reactive

Substances

– Pyrophoric Liquids– Pyrophoric Solids– Self-Heating Substances– Substances which, in

contact with water, emit flammable gases

– Oxidizing Liquids– Oxidizing Solids– Organic Peroxides– Corrosive to Metals

Single Category– Pyrophoric Gases– Combustible Dusts

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GHS Health Hazards10 different health hazard

classifications

– Acute Toxicity– Skin Corrosion/

Irritation– Serious Eye

Damage/Eye Irritation

– Respiratory or Skin Sensitization

– Germ Cell Mutagenicity

– Carcinogenicity

– Reproductive Toxicology

– Target Organ Systemic Toxicity Single Exposure

– Target Organ Systemic Toxicity Repeated Exposure

– Aspiration Toxicity

Single Category– Simple Asphyxiants

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GHS Environment Hazard

– Acute aquatic toxicity– Chronic aquatic toxicity

• Bioaccumulation potential• Rapid degradability

2 different environmental hazard classifications

(optional)

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Exposure

Exposure or exposed = “an

employee is subjected to a hazardous

chemical in the course of employment

through any route of entry and

includes potential (accidental or

possible) exposure”

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Exposurecontinued

• Dose - How much enters your body.– The more hazardous chemical exposure

the greater effect on your body• Sensitivity - How your body reacts.

– Substances effect everyone differently.• Duration - How long you are exposed.

– The longer the exposure, the more your body has a chance to be affected by it.

• How the material gets into the body

– i.e., methods of exposure or routes of entry

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Routes of Entry

• Inhalation• Ingestion• Absorption• Injection

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Routes of Entrycontinued

• Occurs when a chemical is breathed in through the nose or mouth

• Most common method of getting chemicals into the body

Inhalation

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Routes of Entrycontinued

• Through the mouth• Can occur from one’s hands, splash of

the chemical or perhaps a contaminated cigarette placed into the mouth

• Once ingested, the material may spread via the digestive system to other parts of the body

• Important not to eat or smoke in the same area as hazardous chemicals

Ingestion

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Routes of Entrycontinued

Occurs when the material gets on our skin and travels into the bloodstream.

Absorption

(Direct Contact with Skin or Eyes)

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Routes of Entrycontinued

The most vulnerable part of our skin is our eyes.

If corrosive substances come in contact with the eyes, damage can occur very quickly.

Absorption

(Direct Contact with Skin or Eyes)

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Routes of Entrycontinued

Occurs when contaminated sharp objects puncture the skin (cuts, lacerations, needle sticks), introducing hazardous material to the bloodstream. 

Injection

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Personal Protective Equipment (PPE)

Three groups:

Eye protection

Hand and body protection

Masks or Respirators

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Protective Measures

By now, you should have a better understanding of the hazardous properties of chemicals, and how to recognize the hazards of the particular chemicals with which you work.

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Refer to Sample SDS Handout“Chemical Stuff”

(pg. 47-54)

1. Which pictograms will appear on the label?flame, skull and crossbones, corrosion, health hazard

2. What are the possible routes of entry?eyes, skin, inhalation, ingestion

3. What can be done to reduce exposure to the chemical?engineering controls, wear goggles or face shield, wear gloves to protect skin, wear respiratory protection if exposure limits exceeded

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Employer Responsibilities

• Take steps to reduce exposures by providing safer workplaces

• Substitute less hazardous materials

• Establish proper work practices

• Use ventilation to dilute the hazard

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Employee Responsibilities

• Know where to obtain info about Hazardous Chemicals in your work area

• Obtain, read and understand labels/SDSs before you start working

• Ask questions if you are not sure• Keep work area clean• Use required PPE/clothing

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Employee Responsibilities continued

• DO NOT eat, drink or smoke around chemicals

• Practice good personal hygiene practices, e.g. wash hands before eating, drinking, or smoking

• Store incompatible chemicals in separate areas• Learn emergency procedures for your area• Follow procedures for exposure, disposal and

spill clean-up

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Written Program

• May be kept at the primary workplace facility when work is completed at more than one location and the employee must travel between places during a work shift

• Make relative data available upon request to employees

• Should be updated annually

• May be located in the SDS book

Where is your written plan

located?

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Review

Read labels and SDSs

Know where to find the SDSs

Use appropriate PPE

Know correct emergency procedures

Use safe work habits

Maintain and update the program continually

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Sources

• OSHA Haz Com Web Page: www.osha.gov/dsg/hazcom/index.html

• OSHA Guide to GHS: www.osha.gov/dsg/hazcom/ghs.html

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QUESTIONS