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The Globally Harmonized System is Here! Are You Ready?

The Globally Harmonized System is Here! Are You Ready?. Larry K. Seabolt Jr., CHMM Senior Engineer. Hazard Communications Standard / Globally Harmonized System. Title of presentation references Globally Harmonized System

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The Globally Harmonized System is Here! Are You Ready?

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  1. The Globally Harmonized System is Here! Are You Ready? Larry K. Seabolt Jr., CHMM Senior Engineer

  2. Hazard Communications Standard /Globally Harmonized System • Title of presentation references Globally Harmonized System • In actual terms of what has transpired – OSHA has modified the Hazard Communications Standard (HCS) to follow the Globally Harmonized System (GHS) • We in the US will still have a Hazard Communications Standard (HCS) we must follow • The HCS has been revised to follow the EU’s GHS Revision 3

  3. HCS under ghs frame work • Outline: • What does it cover? • Who is affected? • What is the time frame? • What changes are required?

  4. HCS under ghs frame work • What does it cover? • The Globally Harmonized System (GHS) is a revision to the United States current Hazard Communications Standard (HazCom) • It is the system for labeling and classifying hazardous chemicals that we use/store/manufacture/distribute • How we will recognize the hazards of a particular product • How chemicals are classified / grouped

  5. HCS under ghs frame work • What changes are covered? • Hazard Classification • Several chemical classifications under the 1994 HCS were deleted in the HCS 2012 • Combustible liquid, Compressed gas, Explosive, Flammable, Flashpoint, Organic peroxide, Oxidizer, Pyrophoric, Unstable (reactive), and Water-reactive • While the hazards are still evaluated and considered, the 1994 definition and classifications do not exist in the new system • The term “physical and heath hazard” has been replaced with the term “chemical hazard”.

  6. HCS under ghs frame work • What changes are covered? • Labels • All labels are required to contain the pictogram, harmonized signal word and hazard statement • Safety Data Sheets (SDS) • The word “Material” has been dropped and the correct term is now Safety Data Sheet (SDS) • All SDS will be in a 16 section format

  7. HCS under ghs frame work • Who is affected? • Anyone one who deals with hazardous materials, even down to the consumer level • Employees of your facility who may not handle the hazardous materials but have a right-to-know • OSHA estimates that 32 million workers are exposed to 650,000 hazardous chemicals in more than 3 million workplaces

  8. HCS under ghs frame work • What is the time frame? • Final rule adopted March 26, 2012 • Became final May 25, 2012 • Training • Employers have until December 1, 2013 to train employees on new label elements and SDS sheet format (employers are responsible for this)

  9. HCS under ghs frame work • What is the time frame? • Implementation – • June 1, 2015 – Compliance with all modified provisions of the final rule (this applies to chemical manufacturers, importers, distributors and employers) • NOTE: This is also the EU implementation date for classification of all mixtures • Distributors may still ship products under the old label system until December 1, 2015 • December 1, 2015 – All containers must be labeled with a GHS formatted label in order to be shipped • NOTE: DOT markings are NOT changing as part of GHS

  10. HCS under ghs frame work • What is the time frame? • Implementation – • June 1, 2016 – All alternative workplace labeling and hazard communication programs must be updated and functional by this date (employers)

  11. HCS under ghs frame work • What changes are required? • Before December 1, 2013 – • Training needs to be updated to all employees on the new system • It is recommended that charts/posters be used initially to help familiarize employees with the new symbols / warning key words / labels • Depending on what chemicals are being used in your facility, these symbols and words may already be required and are on labels/packaging/SDS now • EU began this process in 1994

  12. HCS under ghs frame work • Hazard Classifications - Changes • The hazard classification definition has been changed • There are specific criteria for classifying health and physical hazards • Mixtures must also be classified • Hazards must be classified by level of severity (from 1 – 4 with 1 being the most severe) – this is different from NFPA labeling structure

  13. HCS under ghs frame work • Hazard Classifications • Only intrinsic hazardous properties of chemicals are considered in the HCS 2012 • Testing is not required to classify chemicals, however, manufacturers and importers are required to properly identify the hazards • Information is listed in Appendix A (health hazard) and Appendix B (physical hazard) of the standard (1910.1200 App A & App B)

  14. Hcs under ghs framework • Hazard Classification • Examples of changes • Flammable liquids are defined differently and the term “combustible liquid” is no longer used • Classifications: • HCS 1994 stated: • "Liquid, flammable" means any liquid having a flashpoint below 100 deg. F (37.8 deg. C), except any mixture having components with flashpoints of 100 deg. F (37.8 deg. C) or higher, the total of which make up 99 percent or more of the total volume of the mixture. • "Combustible liquid" means any liquid having a flashpoint at or above 100 deg. F (37.8 deg. C), but below 200 deg. F (93.3 deg. C), except any mixture having components with flashpoints of 200 deg. F (93.3 deg. C), or higher, the total volume of which make up 99 percent or more of the total volume of the mixture.

  15. HCS under ghs frame work • Label Changes: • Labels on containers (including certain workplace containers) must have the new label(s) • Some categories cover multiple “hazard classifications” we are familiar with through DOT • If the container requires the DOT warning label (for proper shipping), the HCS 2012 pictogram is not required but may be included

  16. HCS under ghs frame work • Label Revisions: • Labels are required to contain certain information: • Product Identifier • Signal Word • Hazard Statement(s) for each hazard class/category • Pictogram(s) • Precautionary Statement(s) • Name, address and phone number of the manufacturer, importer or other responsible party • The company can place other information on the label in addition to the above

  17. Hcs under ghs framework

  18. HCS under ghs frame work • Label Revisions: • Labels on portable containers used for transfers and intended for immediate use by the employee are not required to meet the label requirements • Placards, signs, batch sheets or other identifiers may be used to identify in plant containers in lieu of the required labels.

  19. Hcs under ghs framework • Label Revisions: • Signal Words • Only 2 signal words: Danger & Warning • Danger – used for the more severe hazards • Warning – used for less severe hazards • Precautionary Statements • Covers areas of: • Prevention • Storage • Response • Disposal

  20. Hcs under ghs framework • Safety Data Sheets (SDS) • Safety Data Sheets are required to be in new 16 section format • Section 1 – Identification • Common/trade names, use, synonyms, manufacturer/importer info • Section 2 – Hazard Identification • The new parts of the HCS2012 (signal words, pictograms, precatuionary) • Section 3 – Composition/Ingredients • Chemical name(s), CAS numbers, common identifiers • For mixtures – exact percentages or concentrations are required except for materials claimed under trade secrets or with batch to batch variations – ranges can by used • Section 4 – First Aid • Section 5 – Fire Fighting • Section 6 – Accident release • What to do when…

  21. Hcs under ghs framework • Safety Data Sheets (SDS) • Safety Data Sheets are required to be in new 16 section format • Section 7 – Handling / Storage • Section 8 – Exposure controls • Section 9 – Physical / Chemical Comp • All of the following are minimum requirements on the SDS

  22. Hcs under ghs framework Safety Data Sheets (SDS) Section 9 – Physical / Chemical Comp Appearance (physical state, color, etc.); Upper/lower flammability or explosive limits; Odor; Vapor pressure; Odor threshold; Vapor density; pH; Relative density; Melting point/freezing point; Solubility(ies); Initial boiling point and boiling range; Flash point; Evaporation rate; Flammability (solid, gas); Upper/lower flammability or explosive limits; Vapor pressure; Vapor density; Relative density; Solubility(ies); Partition coefficient: n-octanol/water; Auto-ignition temperature; Decomposition temperature; and Viscosity.

  23. Hcs under ghs framework • Safety Data Sheet (SDS) • Safety Data Sheets area required to be in new 16 section format • Section 10 – Stability and reactivity • In three parts – Reactivity, Chemical Stability and other • Section 11 – Toxicological Information • Routes of exposure, affects of short/long term exposure • Section 12 – Ecological Information – non mandatory • Affects on environment if released • Section 13 – Disposal considerations – non mandatory • RCRA disposal guidance – regulated by EPA • Section 14 – Transport Information – non mandatory • DOT Transportation guidance • Section 15 – Regulatory Information – non mandatory • State / local restrictions or regulations • Section 16 – Other information • Preparation date, revisions, etc.

  24. Hcs under ghs framework • Safety Data Sheet (SDS) • The final rule did include: • The disclosure of exposure limits and the carcinogenic affects of materials contained in the product (these were not part of the proposed rule making) • As with former HCS, SDS must be immediately accessible to the employees from their work areas • May be in hard copy or electronic • Must have a backup in case of power failure or emergency

  25. Hcs under ghs framework • Training Requirements • Just like the HCS 1994 standard, training is required: • At initial work assignment • When new chemical hazards are introduced into the work area • Training must include: • The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified

  26. Hcs under ghs framework • Additional Training Requirements • All affected employees must be updated on the new HCS 2012 portions • The new definitions / hazard classifications of materials • Changes in the definitions • Removal of certain terms we have become familiar with • New pictograms • What do the new symbols mean • How will they be used in the work place / identification of materials

  27. Hcs under ghs framework • Additional Training Requirements • All affected employees must be updated on the new HCS 2012 portions • Signal words • What do the words mean and how are they used • December 1, 2013 is the deadline to have all employees trained on the new system

  28. Hcs under ghs framework • Questions regarding the new changes? • Larry Seabolt, Remtech Engineers • Lseabolt@remtech-eng.com • 770/427-7766 x 202

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