Preparing Your Organization For GHS Compliance

1. Preparing Your Organization For GHS Compliance Frank J Cruice, MS, CSP, CRSP, CHCM Corp. Dir. – Safety & Security Perdue Farms Inc. February 2011

2. Agenda • Review Current Regulatory Trends and Directions • What is GHS and Why Do We Need It? • How GHS Will Affect Your Organization • Key Concerns About GHS Transition • Preparing For GHS • How to Use Technology and Best Practices to Stay on Top of Compliance Changes • Q & A

3. Regulatory Trends and Concerns • Unprecedented Changes Occurring in EHS Regulations • OSHA and EPA with New Leadership/Enforcement • New EPA Administrator, Lisa Jackson • New OSHA Chief, David Michaels • International Regulations Pressuring US Organizations • Decrease in EHS Budgets Creating Compliance Challenges Across the Company

4. What is GHS? • Globally Harmonization System of Classification and Labeling of Chemicals • Globally Harmonized criteria for classifying substances and mixtures according to their health, environmental and physical hazard • Globally Harmonized communicating elements including labels and safety data sheets (SDS)

5. Why Do We Need GHS? • Globally Chemical Business Generates $17 Trillion Per Year • US Generates $450 Billion Annually and Exports $80 Billion • Various Global Regulations are Complex and Expensive Preventing Small/Medium Companies from Competing Globally • Extensive Global Trading Created a Need For Consistent, Standardized Approach for Worker Protection.

6. How Will GHS Affect My Organization • SDSs will replace MSDSs • New Container Labeling Requirements • Chemical Classification • Complete Update of Your Hazard Communication Written Plan • Training of Employees • Timing of GHS Implementation

7. GHS Classifications Physical Hazards Health Hazards Environmental Hazards Explosives Oxidizing Solids Flammable Liquid Skin Irritation Chronic Aquatic Toxicity Carcinogenicity Acute aquatic toxicity

8. Labels carcinogen “Danger” (skull and crossbones) “Warning” (exclamation point) May cause cancer (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard) Do not breath dust/fume/gas/mist/vapors/spray Get medical attention if you feel unwell

9. vs. New SDS Old MSDS 1 Product and company ID Product & Company Hazards identification Hazards identification 2 Composition/information on ingredients Composition/information on ingredients 3 First-aid measures 4 First-aid measures 5 Firefighting measures Firefighting measures 6 Accidental release measures Accidental release measures Handling and storage 7 Handling and storage Exposure controls/personal protection 8 Exposure controls/personal protection 9 Physical and chemical properties Physical and chemical properties Stability and reactivity Stability and reactivity 10 Toxicological information 11 Toxicological information Ecological information 12 Disposal considerations 13 Transport information 14 15 Regulatory information 16 Other information Other information

10. What Are the Key Concerns About GHS Transition? • Cost to Employers to Transition to GHS • Creating Labels for Secondary and Tertiary Containers • SDS Distribution • Training Employees • Updated Chemical Inventories

11. Shocking Statistics on Chemical Compliance • Many Companies Overestimate Their Compliance Levels • The’ Typical’ Facility is 30-50% Compliant (!)

12. One Real-World Compliance Example An EHS-showcase facility of a major metals producer… • Anticipated results: • 70-80% compliance level • 475 active chemicals on record prior to inventory audit • Actual results: • 25.9% compliance level • 17% of anticipated active chemical were actually found • 51% of chemicals found were not in larger corporate DB • 320 chemicals found onsite

13. How Do I Prepare Now For GHS Compliance?

14. Traditional Practices • Extensive use of: • Paper • Spreadsheets • Disparate systems • Human calculations • Manual updating • Out-of-date regulatory information • Inherited responsibility: • Former managements comprehension unknown • Changes not tracked • Even if accurate, will be very time consuming

15. Best Practice Technologies • Extensive use of: • Database • Services • Current regulatory data • Integration • Leverage Software-as-a Service (SaaS) to: • Lower acquisition costs • Minimize I/T impact • Outsource compliance functions, as appropriate

16. GHS Compliance Starts with an Accurate Chemical Inventory • Why You Should Consider Outsourcing Chemical Inventory • Leverage experienced inventory specialists • Cost effective using latest inventory tools • Accurate chemical inventory by location • MSDS/SDS collection updated • Reasons Not To Perform Inventory On Your Own • Lack of tools reduces efficiency • Accuracy questionable • MSDSs/SDSs will still need to be acquired

17. An Automated MSDS/SDS System • Vendor Will Monitor and Keep MSDSs/SDSs Current • Physical and Chemical Properties and Percentages are Stored in a Central Database and Used for all Regulatory Computations • New GHS Labeling Information • Companies Can Attach Additional Information and Documents (i.e. GHS Training Documents) to Chemical Records • Archives are Kept for 30 yrs+

18. GHS Preparation Review • Ensure Chemical Inventories Are Up-To-Date • Prepare to Coordinate with Vendors to Produce SDSs in a Timely Manner (form letters) or Use an MSDS Service Provider • Develop Plan to Implement New GHS Labeling Procedures and Convert Existing Chemical Containers • Update Hazard Communication Program • Plan to Train Employees on GHS • Best Practice Approach Uses Both Software and Services

19. End of Presentation Q & A Session