Globally Harmonized System (GHS)AND Your Hazard Communication Program Hazel HunterProject WorkSAFE
Background • The GHS was adopted by the United Nations in 2002 • Original implementation date for the US was 2008 • OSHA published a notice of proposed rulemaking to update the hazard communication standard in September 2009. • Held public hearings in March of 2010. • Final rule made the Federal Registry March 26, 2012.
Background Negotiated from many different countries, international organizations and stakeholders. Commonly referred to as The Purple Book
What is GHS? Logical, Standardized, Comprehensive approach to the Communication of Chemical Hazards • Purpose is to: • Define health, physical & enviro hazards • Communicate hazard info & protective measures
What is GHS? More of a Right to Understand than a Right to Know Standard
Why is the GHS needed? • No country has the ability to identify and specifically regulate every hazardous chemical product. • 650,000 such products in US. • Adoption of GHS helps address protection needs. • OSHA ppt
8 David Wallace, CIH Sr. Lecturer, Utah State University Nevada Local Section, AIHA March 9, 2011
9 David Wallace, CIH Sr. Lecturer, Utah State University Nevada Local Section, AIHA March 9, 2011
Benefits to GHS • Maintain Consistency • Increase quality of information • Reduce trade barriers • Reduce confusion • Increase comprehension of hazards • Reduce fatalities and injuries • 43 fatalities/year • 585 injuries/year • Help address literacy problems
1910.1200 year 2012 Manufacturers must classify the hazards of their chemicals Employers must provide employees with the information • 1910.1200 e Hazcom Program including: • List of chemicals • Container Labeling • SDS (formerly MSDS) • Training • Hazards and protective measures • Non-routine tasks • Multi-employer workplace • Methods to provide employees access to SDS • Methods to inform other employers of precautions necessary • Method employer will use to inform other employees of labeling system • PPE audit ***********
Dec 1, 2013 June 1, 2016
The Elements of GHS • Classification Criteria • Health and Environmental Hazards • Physical Hazards • Hazard Communication • Labels • Shipping Labels • In house labels • Safety Data Sheets • Training
Hazard Classification The Good News For most of you - The work falls on someone else - • (d) (1) Chemical manufacturers and importers shall evaluate chemicals produced in their workplaces or imported by them to classify the chemicals in accordance with this section. “Employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer……?”
Manufacturer’s responsibility A. Hazard Classification 1. Hazard Category a. Based on available data b. No testing required c. Appendix A in 1910.1200 for health d. Appendix B in 1910.1200 for physical hazard B. Not your burden!
GHS Hazard Classification Using the defined criteria in the Purple Book the manufacturer- Assigns a hazard classification Physical Hazards 16 categories Health Hazards 10 categories Environmental Hazards Mixtures – guidance from the Purple Book Again – not your problem 18
Hazard Classifications Physical Hazards (16) Explosives Flammable Gases Flammable Aerosols Oxidizing Gases Gases Under Pressure Flammable Liquids Flammable Solids Self-Reactive Substances Pyrophoric Liquid 10. Pyrophoric Solids 11. Self-Heating Substances 12. Substances which, in contact with water, emit flammable gases 13. Oxidizing Liquids 14. Oxidizing Solids 15. Organic Peroxides 16. Corrosive to Metals
Hazard Classification – Health Hazards (10) 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 20
Health Hazards 21 *STOT = Specific Target Organ Toxicity
Hazard ClassificationAquatic Environmental Acute aquatic toxicity Chronic aquatic toxicity Bioaccumulation potential Rapid degradability 22
Elements of GHS Shipping Labels– 6 elements: • Product Identifier • Manufacturer/supplier • Pictogram • Signal Words • Hazard Statements • Precautionary Statements
Workplace labels OSHA has not changed the general requirements
Flexibility – but • Must be effective • Must be explained in your Hazcom program
Workplace Labels And I quote, “ Employers may choose to label workplace containers either with the same label that would be on shipped containers ….. under the revised rule, or with label alternatives that meet the requirements of the standard. Alternative labeling systems such as the NFPA 704 hazard rating (the diamond) 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.” page 153 of final rule
Workplace labels Options for the employer: • Create their own workplace labels • Provide all of the required information that is on the label from the manufacturer, • The product identifier and words, pictures, symbols or a combination thereof, signs, placards, process sheets, batch tickets, operating procedures which in combination with other information immediately available to employees, provide specific information regarding the hazards of the chemicals.
Workplace labels must be in English. • Other languages may be added to the label if applicable. Acceptable - • Pictograms with black border • PPE pictograms • Environmental pictograms • Symbols that are not OSHA’s HCS pictograms • May continue to use National Fire Protection (NFPA) diamonds • HMIS labels* * As long as they are consistent with the requirements of the Hazcom Standard and the employee has immediate access to additional information on the specific hazard
Confusion Deep in the guts of the Purple Book hazard the numbering system to indicate how hazardous a chemical is, is opposite the HMIS/NFPA classification. 4 being least hazardous vs HMIS where 4 will kill you.
GHS classification ratings order of severity differ from NFPA and HMIS: HMIS/NFPA 0 = Least Hazardous 4 = Most Hazardous GHS 5 = Least Hazardous 1 = Most Hazardous PPT-016-04 36
Labels (cont.) Nine symbols aka pictograms Includes an “Environment” pictogram 31
Pictograms Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard. The pictogram on the label is determined by the chemical hazard classification.
Health Hazard Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity Benzene Vinyl Chloride Ethylene Oxide Pictograms
Pyrophorics Self – Heating Emits Flammable Gas Self Reactives Organic Peroxides Acetone Paints / stains Fuels Pictograms Flammables
Exclamation Mark Irritant (skin and eye) Skin Sensitizer Acute Toxicity (harmful) Narcotic Effects Respiratory Tract Irritant Cyclohexanone Fiberglass Hazardous Dusts Pictogram
Gas Cylinder Compressed gas Refrigerant gas Air Monitor Calibration Gas SCBA or SCUBA tanks Propane tanks Fire extinguishers? Compressed gases Liquefied gases Pictogram
Corrosion Skin Corrosion/Burns Eye Damage Corrosive to Metals Many Acids Hydrofluoric Acid Battery Zinc Chloride Solution Pictogram
Exploding Bomb Explosives Self – reactive Organic Peroxides Fireworks Ammunition Flares Need more Pictogram
Flame Over Circle Oxidizers Hypochlorite Oxygen Ozone Pictogram
Skull and Crossbones Acute Toxicity (fatal or toxic) Arsenic Chloroform Cyanide Solutions Pictogram
Environment (Non-Mandatory) Aquatic Toxicity Herbicides Insecticides Heavy metals Pictogram
DANGER – defines a serious hazard WARNING – hazard is less dangerous Signal Words
Precautionary Statement • A phrase which describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposures to a hazardous product, or improper storage or handling of a hazardous product • 5 Types of Statements • General • Prevention • Response • Storage • Disposal
Supplemental Information Any additional information • Directions for use • Expiration date • Lot number
Shipping Labels • Product identifier • Signal word • Hazard statement(s) • Pictogram(s) • Precautionary statement(s) • Name, address, and phone number of the responsible party.
DANGER Highly flammable liquid and vapor Causes serious eye irritation Keep away from heat/sparks/open flames/hot surfaces. No smoking. Take precautionary measures against static discharge. Keep cool. Protect from sunlight Keep Container tightly closed. Do not get in eyes, on skin or on clothing. Wear protective gloves/protective clothing, eye protection/face protection. IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. ABC Manufacturer Chemical Avenue Chemical, State 12345-1234 Signal Word Hazard Statement/s Precautionary statement/s Supplemental information Acetone
New – Safety Data Sheets Material Safety Data Sheets
Old OSHA MSDS format 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 50 50