Development of a Worldwide System for Hazard Communication

Tom Hawkinson, CIH, CSP

Global EHS Manager, The Toro Company

The Globally Harmonized System (GHS)

for Hazard Classification and Labeling

What is the GHS?

A common and coherent approach to defining and

classifying hazards, and communicating information on

labels and safety data sheets.

Target audiences include workers, consumers, transport

workers, and emergency responders.

Provides the underlying infrastructure for establishment

of national, comprehensive chemical safety programs.

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Why is the GHS needed?

No country has the ability to identify and specifically

regulate every hazardous chemical product.

For example, in the United States, there are an estimated

650,000 materials.

A uniform system of hazard communication will help

inform all users of a material.

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Major Existing Systems

UN Transport Recommendations

European Union (EU) Directives on Substances and

Preparations (now including REACH)

Canadian Requirements for Workplace, Consumers and

Pesticides

US Requirements for Workplace, Consumers, Pesticides, and

Transportation

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UN Systems

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Principles Of Harmonization

Protections will not be reduced; uniform messages will be key.

All types of chemicals will be covered; will be based on intrinsic properties (hazards) of chemicals.

All systems will have to be changed.

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EU Chemical Regulation

EU Parliament Directive (DSD/DPD)

Transposition by member states into country legislation

Enforcement responsibility of member state

EU Regulation

European Chemical Agency (ECHA)

Directly adopted, force of law throughout EU

Key Regulations

REACH ( Registration, Evaluation, Authorisation and Restriction of

Chemical substances)

CLP – Defines GHS implementation in the EU (Classification, Labeling

and Packaging)

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Timeline for Harmonization

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OSHA GHS GHS Trg Labels/SDS

REACH PreReg >1000 TPY >100 TPY >1TPY

Year 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

CLP Substances DSD DSD/CLP CLP

CLP Mixtures DPD

GHS Page by OSHA

Good guidance

Improved Tools

Fact Sheet

Quick Cards

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GHS Page by OSHA

Good guidance

Improved Tools

Fact Sheet

Quick Cards

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Guidance & Outreach

• Press Release: US Department of Labor's OSHA publishes final

rule to update the Hazard Communication Standard (HCS)

• Guidance

» OSHA Briefs

» Fact Sheet

» Quick Cards

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a) Purpose

HazCom 1994

• All hazards to be evaluated.

• Comprehensive hazard

communication program to

transmit information.

• Preempt state laws.

HazCom 2012

• All hazards to be classified.

• Other provisions the same,

except OSHA added that the

rule is consistent with Revision

3 of the GHS.

• Slight clarifying modification

was made to the language

regarding preemption.

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b) Scope and Application

HazCom 1994

• All chemicals known to be

present are covered.

• Practical accommodations for

special situations.

• Addresses interface with other

Federal laws.

HazCom 2012

• Minimal changes except to

conform terminology, and

remove reference to current

Appendix E which has been

deleted from the standard and a

clarification on Federalism.

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c) Definitions

HazCom 1994

• Includes specific definitions for terms

used in the standard, as well as all

physical hazards.

HazCom 2012

• Physical hazard definitions removed

from paragraph (c), and placed in a

new Appendix B on physical hazard

classification criteria.

• Following terms are also deleted:

flashpoint (methods included in

Appendix B), hazard warning, material

safety data sheets.

• Some definitions are revised to be

GHS-consistent.

• New definitions added for

classification.

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d) Hazard Classification

HazCom 1994

• Performance-oriented

» Definitions in paragraph (c),

Appendices A and B

» Appendix B—parameters for

evaluating data

» “Floor” of chemicals

considered hazardous

» “One study” rule

» Standardized mixture cut-off

rules

HazCom 2012

• Specific and detailed

» Concept of “classification” vs.

determination in current rule

» Each hazard class has detailed

criteria to apply to data on

the chemical

» No floor; based on weight of

evidence

» Mixture rules are specific to

each hazard class

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Hazard Classification

• Each physical or health hazard is a “hazard class” (e.g.,

Carcinogenicity is a hazard class).

• A “hazard class” may be sub-divided in the criteria into several

“hazard categories” based on the degree of severity of the hazard.

• Placing a chemical into a “hazard class” , and where necessary, a

“hazard category”, is the concept of classification—determining

not only the hazard, but also the severity of the effect.

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Hazard Classification, cont. • Manufacturers are still responsible for determining the hazards of

the chemicals they produce or import.

• Classification (similar to hazard determination) is based on the full

range of available information. The procedures for determining if

the manufacturer has properly performed the hazard classification

are provided in Appendix A (health) and Appendix B (physical).

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Health Hazards

Hazard Class Hazard Category

Acute Toxicity 1 2 3 4

Skin Corrosion/ Irritation 1A 1B 1C 2

Serious Eye Damage/ Eye Irritation 1 2A 2B

Respiratory or Skin Sensitization 1

Germ Cell Mutagenicity 1A 1B 2

Carcinogenicity 1A 1B 2

Reproductive Toxicity 1A 1B 2 Lactation

STOT – Single Exposure 1 2 3

STOT – Repeated Exposure 1 2

Aspiration 1

Simple Asphyxiants Single Category

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Physical Hazards Hazard Class Hazard Category

Explosives Unstable Explosives Div 1.1 Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6

Flammable Gases 1 2

Flammable Aerosols 1 2

Oxidizing Gases 1

Gases under Pressure

Compressed Gases

Liquefied Gases

Refrigerated Liquefied Gases

Dissolved Gases

1

Flammable Liquids 1 2 3 4

Flammable Solids 1 2

Self-Reactive Chemicals Type A Type B Type C Type D Type E Type F Type G

Pyrophoric Liquids 1

Pyrophoric Solid 1

Pyrophoric Gases Single category

Self-heating Chemicals 1 2

Chemicals, which in contact with

water, emit flammable gases 1 2 3

Oxidizing Liquids 1 2 3

Oxidizing Solids 1 2 3

Organic Peroxides Type A Type B Type C Type D Type E Type F Type G

Corrosive to Metals 1

Combustible Dusts Single category 19

Hazard Statements

A single harmonized hazard statement for each level of

hazard within each hazard class

Example: Flammable liquids

Category 1: Extremely flammable liquid and vapour

Category 2: Highly flammable liquid and vapour

Category 3: Flammable liquid and vapour

Category 4: Combustible liquid

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Hazards not Otherwise Classified

• This definition was added to ensure that hazards currently covered

by HCS continue to be covered.

• Information will be required on the safety data sheets in Section 2.

• Hazard information on the label, is not mandatory, but can be

provided under supplementary information.

• Such hazards must also be addressed in worker training.

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Simple Asphyxiant and Pyrophoric Gas

• “Simple asphyxiant” means a substance or mixture that displaces

oxygen in the ambient atmosphere, and can thus cause oxygen

deprivation in those who are exposed, leading to unconsciousness

and death.

» Label: Warning. May displace oxygen and cause rapid suffocation.

• “Pyrophoric gas” means a chemical in a gaseous state that will

ignite spontaneously in air at a temperature of 130 degrees F (54.4

degrees C) or below.

» Label: Danger. Catches fire spontaneously if exposed to air.

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Combustible Dust

• Combustible dust is covered separately from HNOC, but is not

specifically defined.

• Guidance for defining combustible dust is to be taken from

existing documents, including the directive for the National

Emphasis Program; the NFPA standards also provide useful

information.

• Combustible dust must be addressed on labels where appropriate:

» Warning. May form combustible dust concentrations in air.

» Paragraph (f)(4) may apply to materials shipped in solid form, that create

combustible dust when processed.

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e) Written Hazard Communication Program

HazCom 1994

Employers must have a

written program describing

how the rule will be

implemented, including a list

of hazardous chemicals,

methods for informing

employees about non-routine

tasks.

HazCom 2012

No changes.

Employers will have to make

sure the program is current

when the new provisions are

implemented (e.g., list of

hazardous chemicals may have

to be updated).

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f) Labels and Other Forms of Warning

HazCom 1994

• Shipped containers to be labeled

with identity, appropriate hazard

warnings, and responsible party.

• Performance-oriented, specifics

left to discretion of chemical

manufacturer or importer.

HazCom 2012

• Shipped containers to be

labeled with product

identifier; signal word; hazard

statement(s); pictograms;

precautionary statements; and

responsible party.

• Specifies information by

hazard class and category.

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OSHA Training Requirements

The first compliance date of the revised HCS

is December 1, 2013. By that time employers

must have trained their workers on the new

label elements and the SDS format.

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OSHA Training Requirements

• GHS has the same objectives as HazComm • Convey hazard • Communicate precautions • Guide use, storage and disposal

• GHS has different methods • Expands the hazard categories • Uses standardized definitions and phrases for hazard

description • Uses standardized (but different) label elements • Uses a standardized SDS format with additional

information requirements (not all used by OSHA)

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Tiered Approach to Classification

Use test data for the mixture (when available)

Use bridging principles, if applicable

For health and environmental hazards, estimate hazards based on the known ingredient information

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Tiered Approach to Classification

Bridging Principles

DNEL (Derived No Effect Level/Do Not Exceed Level)

QSAR (Qualitative Structural Activity Relationships)

Codified in REACH

Applied to new materials, mixtures or materials where not

toxicology has been done

Calculation of DNEL can be quite different than national

occupational standards

Must specify protections for anticipated uses (9 pg IPA MSDS to

103 pg SDS)

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Tiered Approach to Classification

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Labels

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Transport Pictograms

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GHS Pictograms

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Labels

Internal GHS Label

External Transport Label

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Pictogram Shape and Color

For transport, pictograms will have the background and symbol colors currently used.

For other sectors, pictograms will have a black symbol on a white background with a red diamond frame. A black frame may be used for shipments within one country.

OSHA permits this for internal labels

Where a transport pictogram appears, the GHS pictogram for the same hazard should not appear.

OSHA recently revised this to allow both

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Workplace Labeling • OSHA is maintaining the approach used in the current HCS that

allows employers to use workplace-specific labeling systems as

long as they provide the required information.

• However, such workplace label systems may need to be updated to

make sure the information is consistent with the new

classifications.

• NFPA/HMIS Systems

» (ratings systems v. classification)

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Health Standards • Asbestos (1910.1001; 1926.1101;

1915.1001)

• 13 Carcinogens (1910.1003)

• Vinyl Chloride (1910.1017)

• Inorganic Arsenic (1910.1018)

• Lead (1910.1025; 1926.62)

• Chromium (VI) (1910.1026; 1926.1126;

1915.1026)

• Cadmium (1910.1027; 1926.1127)

• Benzene (1910.1028)

• Coke Oven Emissions (1910.1029)

• Cotton Dust (1910.1043)

• 1,2-dibromo-3-chloropropane

(1910.1044)

• Acrylonitrile (1910.1045)

• Ethylene Oxide (1910.1047)

• Formaldehyde (1910.1048)

• Methylenedianiline (1910.1050; 1926.60)

• 1,3-Butadiene (1910.1051)

• Methylene Chloride (1910.1052)

• Occupational exposure to hazardous

chemicals in laboratories (1910.1450)

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Safety Standards • Flammable Liquids (1910.106; 1926.52)

• Spray finishing using flammable and combustible materials (1910.107)

• Process safety management of highly hazardous chemicals (1910.119; 1926.64)

• Hazardous waste operations and emergency response (1910.120; 1926.65)

• Dipping and coating operations: Coverage and definitions (1910.123)

• General requirements for dipping and coating operations (1910.124)

• Additional requirements for dipping and coating operations that use flammable liquids or

liquids with flashpoints greater than 199.4 °F (93 °C) (1910.125)

• Welding, Cutting, and Brazing (1910.252)

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Role of the SDS in the GHS

The Safety Data Sheet (SDS) should provide

comprehensive information about a chemical substance or

mixture.

Primary Use: The Workplace

Employers and workers use the SDS as a source of information

about hazards and to obtain advice on safety precautions.

SDS can be requested by consumers and may be required by supply

chain partners

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SDS Format: 16 headings

1. Identification

2. Hazard(s) identification

3. Composition/information on ingredients

4. First-aid measures

5. Fire-fighting measures

6. Accidental release measures

7. Handling and storage

8. Exposure control/personal protection

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Format: 16 headings (cont.)

9. Physical and chemical properties

10. Stability and reactivity

11. Toxicological information

12. Ecological information

13. Disposal considerations

14. Transport information

15. Regulatory information

16. Other information

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Toro Implementation of GHS Training

Several approaches employed

Key issues

Identifying hazardous materials on site

Providing MSDS/SDS index and access

Delivering training

Keeping adequate records

HazComm consistently one of OSHA’s top ten citations

New requirements will move it to the top of the list

Current challenge: assure everyone is trained by Dec 1, 2013

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Toro Implementation of GHS Training

Strategies

Online training using ResourceNOW

Content current for GHS training

Delivery tests student and delivers certificate

Learning Management System pushes training notice and records

completion

Features include:

Customizable content

Online delivery

Library of resources

LMS

Some Spanish language training

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Toro Implementation of GHS Training

Strategies

Some sites prefer classroom delivery

Language/educational level issues with standard content

Shut-downs and Training Days allow for completion in a single timeframe

Poor support for electronic learning

Inadequate technological equipment base

Inadequate technological skillset among workers

Inadequate support to implement process

Regardless of strategy:

Assure everyone who needs training receives it

Keep good records/follow up with stragglers

Assure MSDS/SDS collection current, indexed and available

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Questions?

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