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GLOBALLY HARMONIZED SYSTEM OF CLASSIFICATION AND LABELING OF CHEMICALS (GHS). David Wallace, CIH Utah ASSE January 14, 2010. 1. Outline. GHS overview OSHA’s GHS activity Proposed changes to the Hazard Communication Standard Effect on Safety professionals. Introduction.

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globally harmonized system of classification and labeling of chemicals ghs

GLOBALLY HARMONIZED SYSTEM OF CLASSIFICATION AND LABELING OF CHEMICALS (GHS)

David Wallace, CIH

Utah ASSE

January 14, 2010

1

outline
Outline
  • GHS overview
  • OSHA’s GHS activity
  • Proposed changes to the Hazard Communication Standard
  • Effect on Safety professionals
introduction
Introduction
  • In 1985, one of my jobs as a “young” Safety Professional was helping my employer comply with OSHA’s new Hazard Communication standard, 1910.1200.
  • Now, it looks like we will need to do it again!
ghs overview
GHS Overview
  • “Globally Harmonized System Of Classification And Labeling Of Chemicals”
  • United Nations guidance for a uniform (harmonized) hazard communication system
  • Based on ”major” existing systems
    • USA and Canadian systems for the workplace, workplace, consumers and pesticides
    • European Union directives for classification and labeling of substances and preparations
    • United Nations Recommendations on the Transport of Dangerous Goods.
ghs overview1
GHS Overview
  • Elements
    • Harmonized criteria forclassifying substances and mixtures according to their health, environmental and physical hazards
    • Harmonized hazard communication elements, including requirements for labeling and safety data sheets.

5

ghs overview2
GHS Overview
  • Justification
    • Label requirements differ, requiring multiple labels for the same product
    • Hazard definitions are not consistent
      • Toxicity, Flammability
    • Globally over 100 diverse hazard communication regulations for their products globally
      • Regulatory compliance is complex and costly
      • Barrier to international trade in chemicals
ghs overview3
GHS Overview
  • Key Guiding Principles of the Harmonization Process
    • Protection will not be reduced
    • Will be based on intrinsic properties (hazards) of chemicals
    • All types of chemicals will be covered
    • All systems will have to be changed
    • Involvement of all stakeholders should be ensured
    • Comprehensibility must be addressed
ghs hazard classification
GHS Hazard Classification
  • Defined criteria are used to assign a hazard classification
    • Physical Hazards
      • 16 categories
    • Health Hazards
      • 10 categories
    • Environmental Hazards
  • Mixtures
    • GHS classification guidance for when chemicals are mixed
ghs hazard classification1
Physical Hazards

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

GHS Hazard Classification
ghs hazard classification2
Health Hazards

Acute Toxicity

Skin Corrosion/Irritation

Serous 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

GHS Hazard Classification
ghs hazard classification3
GHS Hazard Classification
  • Hazardous to the Aquatic Environment
    • Acute aquatic toxicity
    • Chronic aquatic toxicity
      • Bioaccumulation potential
      • Rapid degradability
ghs hazard communication
GHS Hazard Communication
  • Labels
    • Symbols (hazard pictograms)
      • Examples:
    • Signal Words
      • “Danger” or “Warning”
    • Hazard Statements
      • Example: “Toxic if swallowed”
    • Other
      • Precautions, identification, supplier, supplemental
ghs hazard communication1
GHS Hazard Communication
  • GHS Safety Data Sheet (SDS)
    • 16 headings
    • Similar to ISO, EU, and ANSI MSDS/SDS requirements
osha msds format old
OSHA MSDS Format (old)
  • OSHA-174 (1989), 8 sections (non-mandatory)
    • Manufacturer information
    • Hazard Ingredients/Identity Information
    • Physical/chemical properties
    • Fire and Explosion Hazard Data
    • Reactivity Data
    • Health Hazard Data
    • Precautions for Safe Handling and Use
    • Control Measures

16

ansi msds format
ANSI Z400.1-2004

Product and Company Identification

Hazard Identification

Composition / Information On Ingredients

First Aid Measures

Fire Fighting Measures

Accidental Release Measures

Handling and Storage

Exposure Control / Personal Protection

Physical and Chemical Properties

Stability and Reactivity

Toxicological Information

Ecological Information

Disposal Considerations

Transport Information

Regulatory Information

Other Information

ANSI MSDS Format

17

osha and the ghs
OSHA and the GHS
  • Rulemaking Steps
    • ANPR- Sept. 12, 2006
    • Notice of Proposed Rulemaking – Sept. 30, 2009
      • Public Comment Period – ended Dec. 29. 2009
      • Public Hearing – (Notice published Dec. 29, 2009)
        • March and April, 2010 for Washington, Pittsburgh and Los Angeles
      • Post-hearing Comment Period
    • Final Standard
    • Phase-in Period for Compliance
proposed osha rule
Proposed OSHA Rule
  • Major changes to the Hazard Communication Standards
    • Changed “hazard determination” to “hazard classification”
    • Changed “MSDS” to “SDS”
    • Changed definitions to comply with GHS
    • Labels for shipped containers required to have GHS information
      • Workplace labels may be GHS labels, or other labels that identify the material and hazard
    • Safety Data Sheets with 16-sections
      • May include guidance for transportation information and environmental hazards
proposed osha rule1
Proposed OSHA Rule
  • Major changes to the Hazard Communication Standards (cont.)
    • Other OSHA standards are changed where applicable
      • New wording on warning signs for asbestos and other health hazards
      • Changes to standards for HAZWOPER, Combustible and Flammable Liquids, Welding Cutting and Brazing, etc.
proposed osha rule2
Proposed OSHA Rule
  • Effective dates
    • Two years after final rule
      • Employee training on new labels and safety data sheets
    • Three years after final rule
      • Chemical manufacturers, importers, distributors, and employers in compliance with all modified provisions
proposed osha rule3
Proposed OSHA Rule
  • Costs and benefits
    • $97 million annual cost
      • training, SDSs & labels, management
    • $851 million annual benefit
      • reduced injuries/illnesses/fatalities, improved productivity and cost reduction
    • $754 million net annual benefit
osha interpretation
OSHA interpretation
  • GHS labels comply with current OSHA requirements
    • Standard Interpretations 10/06/2009 - Using the Globally Harmonized System (GHS) to Comply with OSHA's Hazard Communication Standard
    • http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27218
comments on the proposed rule
Comments on the proposed rule
  • OSHA specifically solicited comments about:
    • Costs and benefits
    • Effect on “small entities”
    • GHS classification system
    • Combustible dusts and Simple asphyxiants
    • Color labels vs. B&W
    • PELs on data sheets
    • Etc.
  • 475 items in the docket (12/29/09)
asse s comment
“ASSE applauds OSHA for its leadership in undertaking this rulemaking and urges that every possible step be taken to achieve a final rule as soon as practicable.”

However, ASSE has some concerns:

OSHA should include “control banding”

OSHA underestimated the impact on small business

Some hazard classifications should be modified

OSHA should require red borders on labels

Labels should have more required information

Exposure limits should be listed on data sheets

The new standard should have a shorter deadline for training

There may be a shortage of SH&E professional on staff

Etc.

ASSE’s Comment
slide26
Online news magazine features GHS
    • “As the United States creeps closer to adopting the Globally Harmonized Hazard Communication System (GHS), companies must be prepared to comply with the new provisions.”
    • http://ehstoday.com/fire_emergencyresponse/hazardous-materials/ghs-power-one/
effect on safety professionals
Effect on Safety Professionals
  • Become familiar with the new system
  • Collect new SDSs as provided by suppliers and incorporate them into the existing MSDS system (or use commercial service)
  • New GHS labels for “shipped containers”
    • Employers can use other systems for workplace labeling
  • Train employees on new labels and SDS
resources
Resources
  • GHS Websites
    • OSHA, http://www.osha.gov/dsg/hazcom/global.html
    • EPA, http://www.epa.gov/oppfead1/international/globalharmon.htm
    • DOT http://www.phmsa.dot.gov/hazmat/regs/international
    • CSPC, http://www.cpsc.gov/phth/GHSpolicy.html
    • UN, http://www.unece.org/trans/danger/publi/ghs/ghs_rev02/02files_e.html
  • Government Printing Office
    • http://www.gpoaccess.gov/
  • OSHA comments
    • Docket No. OSHA-H022K- 2006-0062 at http://www.regulations.gov