Globally Harmonized System of Classification and Labelling of Chemicals (GHS) UpdateThe OSHA Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update to the Hazard Communication Standard (HCS) will provide a common and coherent approach to classifying chemicals and communicating hazard information based on labels and safety data sheets. The revised MIOSHA Part 42, 92 and 430 Hazard Communication standard will improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals. This update with also help reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store and use hazardous chemicals with providing cost savings for American businesses that periodically update safety data sheets and labels for chemicals covered under the Hazard Communication Standard.

Michigan Department of Licensing and Regulatory AffairsMichigan Occupational Safety & Health AdministrationConsultation Education & Training Division

Suggested Format for a Written Hazard Communication Program

----------------------------------------------------------------------------------------

General

The following hazard communication program has been established for _______________________________. This program will be available for review for all employees.Hazard Classification

Chemical manufacturers or importers shall evaluate chemicals they produced or import to classify the chemicals in accordance with the revised Hazard Communication Standard.Effective June 1, 2015 – For each chemical, the chemical manufacturer or importer shall determine the hazard classes, and where appropriate, the category of each class that apply to the chemical being classified. This information will be placed in the Material Safety Data Sheet/Safety Data Sheet (MSDS/SDS) and on the product label.____________________________________ will rely on MSDS/SDSs obtained from product suppliers to determine which chemicals are classified as hazardous for employees.Labeling

A. _____________________________________ will be responsible for seeing that all containers entering the workplace from a manufacturer, importer or distributer are properly labeled.

B. All labels shall be checked for:Current requirements: Requirements effective June 1,

20151. Identity of the material.2. Appropriate hazard

label warning for the material

3. Name and address of responsible party. (Only if the container is received from the manufacturer, distributor, or importer.)

1. Product identifier;2. Signal word;3. Hazard statement(s);4. Pictograms(s);5. Precautionary statement(s);

and,6. Name, address, and

telephone number of the chemical manufacturer, importer, or other responsible party.

C. Each _________________________________ shall be responsible for ensuring that all secondary containers used in their work area are labeled with the appropriate product identifier and provide employees with the specific information regarding the physical and health standards of the hazardous chemical.

Note: Workplace labeling. The employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either:The information specified for labels on shipped containers; OR, product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.

Safety Data Sheets

Changes to MSDS/SDS format effective June 1, 2015 - Chemical manufacturers or importers shall ensure that MSDS/SDSs for their products include the following Sections in order:

Section 1, Identification;Section 2, Hazard(s) identification;Section 3, Composition/information on ingredients;Section 4, First-aid measures;Section 5, Fire-fighting measures;Section 6, Accidental release measures;Section 7, Handling and storage;Section 8, Exposure controls/personal protection;Section 9, Physical and chemical properties;Section 10, Stability and reactivity;Section 11, Toxicological information;Section 12, Ecological information;Section 13, Disposal considerations;Section 14, Transport information;Section 15, Regulatory information; andSection 16, Other information, including date of preparation or last revision.

A. _________________________ will be responsible for compiling and maintaining the master MSDS/SDS file. The file will be kept in/at ______________________.

B. Additional copies of MSDS/SDSs for employee use are located in/at_____________________.

C. MSDS/SDSs will be available for review to all employees during each work shift. Copies will be available upon request to _____________________.

D. Posters identifying the person responsible maintaining MSDS/SDSs and where the MSDS/SDSs are located are posted at _______________________. Posters notifying employees when new or revised MSDS/SDSs are received will be located in the same location(s).

E. If a required MSDS/SDS is not received, ____________________ shall contact the supplier, in writing, to request the MSDS/SDS. If an MSDS/SDS is not received after two such requests, _________________________ shall contact the MIOSHA’s Construction Safety and Health Division at 517-322-1856 or General Industry Safety and Health Division (GISHD) at 517-322-1831, for assistance in obtaining the MSDS/SDS.

The MIOSHA program does not maintain a library of MSDS/SDSs. However, either of the above divisions will assist an employee in obtaining a copy of an MSDS/SDS by contacting the employer or supplier.

Employee Information and Training

A. __________________________________ shall coordinate and maintain records of employee hazard communication training, including attendance rosters.

B. Before their initial work assignment, each new employee will receive hazard communication training. This will include the following information and training:Information:

The requirements of the MIOSHA Hazard Communication Standard

All operations in their work area where hazardous chemicals are present.

Location and availability of the written hazard communication program, the list of hazardous chemicals, and the MSDS/SDS

Training: Methods and observations that can be used to detect

the presence or release of hazardous chemicals in the work area;

The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;

Measures the employees should take to protect themselves from these hazards;

Details of the hazard communication program- including an explanation of the new label elements [product identifier; signal word; hazard statement(s); pictogram(s); and precautionary statement(s)] on shipped containers and the workplace labeling system used by their employer; the new SDS format/sections; and,

How employees can obtain and use hazard information

C. The employee shall be informed that:

1. The employer is prohibited from discharging, or discriminating against, an employee who exercises his/her rights to obtain information regarding hazardous chemicals used in the workplace.

2. As an alternative to requesting an MSDS/SDS from the employer, the employee can seek assistance from the MIOSHA Construction Safety and Health Division at 517-322-1856, or the MIOSHA General Industry Safety and Health Division at 517-322-1831, to obtain the desired MSDS/SDS. A sign or MIOSHA poster will be posted with the address and telephone number of the MIOSHA Divisions responsible for such requests.

D. Before any new physical or health hazard is introduced into the workplace, each employee who may be exposed to the substance will be given information in the same manner as during hazard communication training.

Hazardous Non-routine Tasks (Delete section if not applicable.)A. Occasionally, employees are required to perform non-routine

tasks (i.e., clean reactor vessels, enter confined spaces, etc.) Prior to starting work in such areas, each employee will be given information about the hazards of the area or procedure. This information will include:

1. Specific chemical hazards.2. Protection/safety measures the employee can take to

lesson risks of performing the task.3. Measures the company has taken to eliminate or

control the hazard, including:a. air monitoring,b. ventilation requirements,c. It is the policy of _________________________ that no

employee will begin performance of a non-routine task without first receiving appropriate safety and health training.

d. use of respirators,e. use of attendants to observe procedures, and

f. emergency procedures.B. Hazardous non-routine tasks we have at our facility include:

List hazardous non-routine tasks.

Multi-Employer Worksites – Informing Contractors

A. If our company exposes any employee of another employer to any hazardous chemicals that we produce, use, or store, the following information will be supplied to that employer:

1. The hazardous chemicals they may encounter.2. Measures their employees can take to control or eliminate exposure to the hazardous chemicals.3. The container and pipe labeling system used on-

site.4. Where applicable MSDS/SDSs can be reviewed or obtained.

B. Periodically, our employees may potentially be exposed to hazardous chemicals brought on our site by another employer. When this occurs we will obtain from that employer information pertaining to the types of chemicals brought on-site, and measures that should be taken to control or eliminate exposure to the chemicals.

C. It is the responsibility of_________________________ to ensure that such information is provided and/or obtained prior to any services being performed by the off-site employer. To ensure that this is done the following mechanism will be followed: List all method(s) used to ensure the required information is provided or obtained:

___________________________________________________________________________

Pipes and Piping Systems

Information on the hazardous contents of pipes and piping systems will be identified by: List means of identification for pipes and piping systems (i.e., label, sign, placard, written operating instructions, process sheet, batch ticket, etc.). Natural gas, steam, and compressed air lines (with pressures exceeding 25 psig) must be identified in all industrial facilities. ANSI A13.1-1981 recommends the following colorations: blue for low-medium pressure oxygen and compressed air lines, yellow for variable-high pressure oxygen and compressed air lines, and yellow for acetylene and natural gas lines.

List of Hazardous Chemicals

A list of hazardous chemicals used by _______________________is located_________________________. Further information regarding any of these chemicals can be obtained by reviewing its respective MSDS/SDS.

Materials which can be purchased by the ordinary household consumer, and which are used for the intended purpose and amount as by the ordinary household consumer, are not required to be included in this list. (It is suggested that you maintain a separate list of materials you consider to be “consumer use” materials.)

NOTE: This sample program is applicable to most employers in Michigan. The federal OSHA Hazard Communication Standard (29CFR 1910.1200, effective date May 25, 2012) contains information of particular interest to employers such as retailers, wholesalers, warehouses and employers who work at multiple job sites. All employers are strongly recommended to read the new hazard communication standard to determine its applicability to their workplace. Copies of the standard can be obtained by contacting:

Michigan Department of Licensing and Regulatory AffairsMichigan Occupational Safety and Health AdministrationManagement and Technical Services Division

MIOSHA Standards Section 517-322-1845

Consultation Education and Training Division 517-322-1809

FREE ONSITE CONSULTATION SERVICE FOR EMPLOYERSTo help employers better understand and voluntarily comply with the MIOSHA Act, free Onsite Consultation programs are available to help small employers identify and correct potential safety and health hazards.

Michigan Occupational Safety and Health AdministrationConsultation Education & Training Division

7150 Harris Drive P.O. Box 30643Lansing, Michigan 48909-8143

For further information or to request consultation, education and training services, call (517)322-1809

or visit website at www.michigan.gov/miosha

www.michigan.gov/lara

LARA is an equal opportunity employer/program.Auxiliary aids, services and other reasonable accommodations are available upon request to

individuals with disabilities.

THIS DOCUMENT IS AVAILABLE UPON REQUEST IN ALTERNATIVE FORMATS TO INDIVIDUALSWITH DISABILITIES. FOR FURTHER INFORMATION CALL:

Voice: 517-322-1809 TTY: 517-335-0191

Michigan Department of Licensing and Regulatory AffairsMichigan Occupational Safety & Health AdministrationConsultation Education & Training Division

Hazard Communication – Aligning with the Globally Harmonized System of

Classification and Labeling of Chemicals (GHS)

OVERVIEW OF MAJOR CHANGES TO THE HAZARD COMMUNICATION STANDARD (HCS)

The three major areas of change are in hazard classification, labels, and safety sheets.

Hazard classification; the term “hazard determination” has been changed to “hazard classification”. The “hazard classification” approach in the revised HCS is quite different. Chemical manufacturers and importers shall evaluate chemicals produced in their workplaces or imported by them and determine the hazard classes and where appropriate, the category of each class that apply to the chemical being classified. In doing so, they shall identify and consider the full range of available scientific literature and evidence concerning the potential hazards. There is no requirement to test the chemical to determine how to classify its hazards. The revised HCS has specific criteria for each health and physical hazard, along with detailed instructions for hazard evaluation. It also establishes both “hazard classes” and “hazard categories” – for most of the effects; the classes are divided into categories that reflect the relative severity of the effect. OSHA has included the general provisions for hazard classification in paragraph (d) of the revised rule, and added extensive appendixes (Appendix A – for health hazards and Appendix B – for physical hazards) that address the criteria for each health or physical effect. Labels; Chemical manufacturers and importers shall provide a label that includes a:* Product Identifier* Supplier Identifier* Precautionary statement(s)

* Pictogram

* Signal word (Warning or Danger)

* Hazard statement for each hazard class and category

Pictogram; a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the HCS. The exception being, the environmental pictogram, as environmental hazards are not within OSHA’s jurisdiction. Pictograms must have red borders.

The hazard pictograms and their corresponding hazards are shown below.

HCS Pictograms and Hazards

Signal Words: A single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are “Danger” and “Warning”. “Danger” is used for the more severe hazards, while “Warning” is used for less severe hazards.

Hazard Statement: 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.

Precautionary Statement: A phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical.Safety Data Sheets (SDSs): Will now have a 16-section format. A material safety data sheet (MSDS) is now referred to as a safety data sheet (SDS).Paragraph (g) of the final rule indicates the headings of information to be included on the SDS and the order in which they are to be provided. In addition, Appendix D indicates what information is to be included under each heading. The SDS format is the same as the ANSI standard format which is widely used in the U.S. and is already familiar to many employees.The format of the 16-section SDS must include the following sections:

Section 1. IdentificationSection 2. Hazard(s) identificationSection 3. Composition/information on ingredientsSection 4. First Aid measuresSection 5. Fire fighting measuresSection 6. Accidental release measuresSection 7. Handling and storageSection 8. Exposure controls/personal protectionSection 9. Physical and chemical propertiesSection 10. Stability and reactivitySection 11. Toxicological informationSection 12. Ecological informationSection 13. Disposal considerationsSection 14. Transport information Section 15. Regulatory information

Section 16. Other information, including date of preparation or last revision

Sections 12-15 may be included in the SDS, but are not required by OSHA.RESOURCE INFORMATION:Information related to the changes affecting OSHA’s Hazard Communication Standard can be found on OSHA’s website at http://www.osha.gov/dsg/hazcom/index.html .

OSHA Fact Sheet – Summarizing Changes to Hazard Communication Standard Final Rule Fact Sheet OSHA Quick Card - Labeling OSHA Quick Card & OSHA BRIEF – Safety Data SheetsOSHA Quick Card – PictogramsSide by Side Comparison of Existing and Revised HCS

HCS/GHS Final Rule [PDF 2.33 MB]Federal Register: The final rule was filed on March 20th at the Office of the Federal Register and available for viewing on their Public Electronic Inspection Desk. The Federal Register published the final rule on March 26, 2012. The effective date of the final rule is 60 days after the date of publication.

The table below summarizes the phase-in dates required under the revised Hazard Communication Standard (HCS):

Revised 2012 Hazard Communication Standard

Frequently Asked Questions (FAQs)

Q. What are the major changes to the Hazard Communication Standard?

A. The three major areas of changes are in hazard classifications, labels, and safety data sheets.

Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result.

Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.

Safety Data Sheets: Will now have a specified 16-section format.

The GHS does not include harmonized training provisions, but recognizes that training is essential to an effective hazard communication approach. The revised Hazard Communication Standard (HCS) requires that workers be re-trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safety data sheets.

For a side-by-side comparison of the current HCS and the final revised HCS please see OSHA’s hazard communications safety and health topics webpage at: www.osha.gov/dsg/hazcom/index.html.

Q. What Hazard Communication Standard provisions are unchanged in the revised HCS?

A. The revised Hazard Communication Standard (HCS) is a modification to the existing standard. The parts of the standard that did not relate to the GHS remain relatively unchanged as follows:

Scope Exemptions Workplace (secondary container) Labeling Written Program Elements

Q. Does this new regulation apply to chemicals used in construction?A. The MIOSHA Hazard Communication Standard has always applied to construction and still does. The requirements applicable to construction work are identical to those set forth at 1910.1200 which MIOSHA adopted verbatim.

Q. Why must training be conducted prior to the compliance effective date?

A. OSHA/MIOSHA is requiring that employees are trained on the new label elements (i.e. pictograms, hazard statements, precautionary statements, and signal words) and SDS format by December 1, 2013, while full compliance with the final rule will begin in 2015. This is because American workplaces will soon begin to receive labels and SDSs that are consistent with the GHS, since many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDSs. It is important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they will be familiar with them, understand how to use them, and access the information effectively.

Q. As a chemical manufacturer, importer or employer how often do we need to update the SDSs?

A. The chemical manufacturer, importer or employer preparing the safety data sheet shall ensure that the information provided accurately reflects the scientific evidence used in making the hazard classification. If the chemical manufacturer, importer or employer preparing the safety data sheet becomes newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards, this new information shall be added to the safety data sheet within three months. If the chemical is not currently being produced or imported the chemical manufacturer or importer shall add the information to the safety data sheet before the chemical is introduced into the workplace again. Chemical manufacturers or importers shall ensure that distributors and employers are provided an appropriate safety data sheet with their initial shipment and with the first shipment after a safety das sheet is updated.

Q. Am I required to keep the old MSDS after I receive the new 16-Section Safety Data Sheet (SDS)?

A. Material Safety Data Sheets (MSDSs) are to be replaced with SDSs as soon as they become available from the manufacturer since these would be considered revised MSDS/SDSs. The MSDSs replaced with SDSs are required to be archived and kept for 30 years. Alternatively, Part 470 Employee Medical Records and Trade Secrets, R 325.3457 Preservation of employee exposure

records, Rule 7 (b) gives the employer the option of maintaining a record of the identity of the substance or agent, such as the chemical name if known, where it was used, and when it was used and retaining this information for not less than 30 years (in lieu of archiving the MSDS/SDS itself).

Q. When must label information be updated?

A. Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information. If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.

Q. I have chemicals purchased before the GHS changes with old labels that re not compliant with the revised standard. Do I have to re-label these chemicals?

A. No, employers/employees using hazardous chemicals are not required to re-label old, original chemical containers provided by the manufacturers unless there is a significant change in hazard information as follows:

1910.1200 Hazard Communication: (f) “Labels and other forms of warning”.(11) Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant

information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information. If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.

For additional information see OSHA Brief on Labels and Pictograms: http://www.osha.go/Publications/OSHA3636.pdf

Q. Will shipping containers be required to have BOTH DOT AND MIOSHA pictograms on the label?

For primary containers that are also the shipping container (i.e. 55 gallon drums), it is required that the manufacturer comply with both DOT and MIOSHA labeling. However, in cases where the DOT label/pictogram represents hazards that are the same as the MIOSHA pictogram, the DOT label/pictogram may be used in lieu of MIOSHA pictogram. Pictograms that are not part of DOT regulations include:

Health Hazard(chronic, carcinogen, target organ)

Acute Toxicity(less severe = exclamation pictogram)

If these are applicable to the chemical, they must be placed on the drum in addition to the DOT pictograms. Both DOT and MIOSHA pictograms may be placed on the container at the discretion of the manufacturer. For additional information, refer

!

to the following OSHA webpage: www.osha.gov/dsg/hazcom/ghs.html

Q. Can we still use the HMIS labeling system to label our portable, workplace (secondary) containers? How will workplace secondary container labeling provisions change under the revised Hazard Communication Standard?

A. Yes. You may continue to use the HMIS labeling system for labeling workplace secondary containers.

Excerpt from the updated Hazard Communication Standard:

(6) Workplace labeling. Except as provided in paragraphs (f) (7) and (f) (8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either:

(i) The information specified under paragraphs (f) (1) (i) through (v) of this section for labels on shipped containers (same label information as the original container); OR

(ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical (e.g. HMIS or other labeling system).

Alternative labeling systems (e.g. HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent with the revised HCS (e.g., no conflicting hazard warnings or pictograms).

Q. Are the NFPA and HMIS ratings changing to align with the revised Hazard Communication Standard and GHS?

A. National Fire Protection Association (NFPA) and Hazardous Materials Identification System (HMIS) labeling systems are independent from OSHA/MIOSHA. The American Coatings Association (ACA) revised the HMIS label system in 2001 to the “HMIS® III”. In this system, the “Reactivity” (yellow) section was changed to “Physical Hazard” with additional criteria. The HMIS® numerical rating of 0-4 with 4 being most hazardous still applies. Cross reference charts are being developed by ACA to enable those responsible for classifying chemicals under the revised Hazard Communication Standard to provide HMIS ratings based on GHS hazard classification. Refer to the American Coatings Association website for additional information: www.paint.org/programs/hmis.

Q. HMIS labels are currently rated 0-4 (least severe to most severe). Do all these ratings need to be changed to 1-4 (most severe to least severe in line with GHS hazard categories) to match the new SDS format?

A. No! You may continue to use the HMIS label system for labeling workplace secondary containers. Follow the system ratings as outlined by the American Coating Association. Employees may never see the GHS numerical hazard category representation to know that 1 is most severe and 4 is least severe

under GHS as this information will not appear on manufacturers labels. It may or may not appear in the SDS. As long as employees affected understand the difference between GHS and HMIS or NFPA should they encounter information that shows this difference, this meets the requirement in the HCS.

Q. Is MIOSHA revising the signage requirements stated in certain substance specific Standards (e.g. Lead)?

A. Several MIOSHA standards have or will be changing due to the revision to the Hazard Communication Standard. Standards that require placement and language for labels and signs will be changing (i.e. Lead, Asbestos, Cadmium, and others with chemical specific label and signage requirements). Under these standards, changes to label language, is effective June 1, 2015 and changes to signage is effective June 1, 2016. Additional information can be found at the following links:Standards to change: http://www.michigan.gov/documents/lara/lara_miosha_cet5532_409584_7.docSignage to change:http://www.michigan.gov/documents/lara/lara_miosha_cet5533_409585_7.doc

Q. May the International Agency for Research on Cancer (IARC) and the National Toxicology Program (NTP) lists be used to make carcinogen classifications and will it be required on Safety Data Sheets (SDS)?

A. In the revised Hazard Communication Standard (HCS), OSHA/MIOSHA has provided classifiers with the option of relying on the classification listings of IARC and NTP to make

classification decisions regarding carcinogenicity, rather than applying the criteria themselves. This should make classification easier for classifiers, as well as lead to greater consistency. In addition, OSHA/MIOSHA has provided in non-mandatory Appendix F of the revised rule, guidance on hazard classification for carcinogenicity.

IARC and NTP classifications have been retained. Therefore, if a chemical is listed as a carcinogen by either IARC or NTP, it must be noted on the SDS. Additionally, if OSHA/MIOSHA finds a chemical to be a carcinogen, it must be noted on the SDS as well.

Q. How has OSHA/MIOSHA addressed pyrophoric gases, simple asphyxiants, combustible dust hazards and other hazards not classified in GHS?

A. In the revised HCS, OSHA/MIOSHA has added pyrophoric gases, simple asphyxiants and combustible dust to the definition of “hazardous chemical.”Pyrophoric gases: OSHA/MIOSHA has retained the definition for pyrophoric gases from the current HCS. Pyrophoric gases must be addressed both on container labels and SDSs. Label elements for pyrophoric gases include the signal word “danger” and the hazard statement “catches fire spontaneously if exposed to air.”Simple asphyxiants: In the final HCS, simple asphyxiants must be labeled where appropriate, and be addressed on SDSs. Label elements for simple asphyxiants include the signal word “warning” and the hazard statement “may displace oxygen and cause rapid suffocation.”Combustible dust: OSHA/MIOSHA has not provided a definition for combustible dust to the final HCS given ongoing activities in the specific rulemaking, as well as in the United Nations Sub-

Committee of Experts on the GHS (UN/SCEGHS). However, guidance is being provided through existing documents, including the Combustible Dust National Emphasis Program Directive CPL 03-00-008, which includes an operative definition, as well as provides information about current responsibilities in this area. In addition, there are a number of voluntary industry consensus standards (particularly those of the NFPA) that addresses combustible dust.

In the final HCS, combustible dust hazards must be addressed on labels and SDSs. Label elements are provided for combustible dust in the final HCS and include the signal word “warning” and the hazard statement “May form combustible dust concentrations in the air.”

For chemicals in a solid form that do not present a combustible dust hazard, but may form combustible dusts while being processed in normal downstream uses, paragraph (f) (4) of the HCS allows the chemical manufacturer some flexibility in labeling requirements. The manufacturer or importer may transmit the label to the customer at the time of the initial shipment, but the label does not need to be included with subsequent shipments unless it changes. This provides the needed information to the downstream users on the potential hazards in the workplace, while acknowledging that the solid metal or other materials do not present the same hazards that are produced when these materials are processed under normal conditions of use.

Hazards not otherwise classified (HNOC):All other chemicals for which there is a hazard but the hazard does not fit any other classification are called HNOC. These hazards will not be required to be disclosed on the label but will

be required to be disclosed in Section 2 of the Safety Data Sheet (SDS). This reflects how GHS recommends these hazards should be disclosed. Chemical manufacturers and importers are expected to assess these hazards when they are conducting their hazard evaluation of physical and health hazards.

LARA is an equal opportunity employer/program.Auxiliary aids, services and other reasonable accommodations are available upon request to individuals with disabilities.

Consultation Education & Training (CET) Divisionwww.michigan.gov/miosha (517)322-1809CET-0186 Revised 04/15/13