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OSHA’s Revised Hazard Communication Standard: What You Need to Do Now to Comply with HazCom 2012!. Chuck Haling. Vice President of Sales, MSDSonline. Goals for this Presentation. Avoid This…. Brief Review of OSHA’s HCS Discuss OSHA’s Alignment with the GHS

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slide1

OSHA’s Revised Hazard Communication Standard:

What You Need to Do Now to Comply with HazCom 2012!

chuck haling

Chuck Haling

Vice President of Sales, MSDSonline

goals for this presentation
Goals for this Presentation
  • Avoid This….
  • Brief Review of OSHA’s HCS
  • Discuss OSHA’s Alignment with the GHS
  • Understand reasons for adoption
  • Learn how to comply
what is hcs
What is HCS?
  • An OSHA Regulation
slide5
`

A.K.A…

slide6

HCS

HazCom Standard

Hazard Communication

Right-to-Know

1910.1200

The HazComReg

RTK

The Reg

29 CFR 1910.1200

HazCom

what is hcs1
What is HCS?
  • Hazard Communication Standard
  • An OSHA Regulation – protect workers from hazardous chemicals
  • Adopted in 1983
  • Covers 43+ Million U.S. Workers
  • 5 Million Workplaces
  • Over 880,000 Chemicals
purpose of hcs
Purpose of HCS

“…to ensure hazardsof all chemicals produced or imported are evaluated and detailsregarding their hazards are transmittedto employers and employees”

“Ensure requirements are consistentnationwide”

hcs main requirements
HCS Main Requirements

Written Plan

Chemical Inventory

Labels & Warnings

Training

MSDS Documents

1

2

3

4

5

chemicals covered old hcs
Chemicals Covered – Old HCS
  • Physical Hazards
    • Combustible Liquids
    • Compressed Gases
    • Explosives
    • Flammables
    • Organic Peroxides
    • Oxidizers
    • Pyrophorics
    • Unstable (Reactive) Materials
    • Water-Reactives
chemicals covered old hcs1
Chemicals Covered – Old HCS
  • Health HazardsChemicals that may produce acute or chronic health effects in exposed employees.
  • Carcinogens
  • Toxic agents
  • Reproductive toxins
  • Irritants
  • Corrosives
  • Sensitizers
  • Hepatotoxins
  • Nephrotoxins
  • Neurotoxins
  • Agents which act on the hematopoietic system
  • Agents which damage the lungs, skin, eyes or mucous membranes
who has responsibilities
Who has Responsibilities
  • Chemical Manufacturers
    • Evaluate and now also classify hazards of chemicals
    • Provide labels & MSDSs to employers to which they ship chemicals
  • Importers & Distributors
    • Provide labels & MSDSs to employers to which they ship chemicals
  • Employers Who “Use” Chemicals

Are responsible for the following as part of a compliant HazCom program:

    • Written Hazard Communication Plan / Program
    • Written Chemical Inventory
    • Ensuring proper use of Labels and Warnings
    • Maintaining MSDSs and providing Right-to-Know access to employees
    • Providing Employee Training
the problem
The Problem

When it comes to Hazard Communication…

  • Regulations vary widely internationally
    • E.g., U.S. has HazCom Standard, Canada has WHMIS, Europe has CLP
  • Different agencies within the same country may have jurisdiction over hazardous chemical use and safety
    • E.g., in the U.S.: EPA, DOT, OSHA, Consumer Product Safety Commission
  • Multiple labels & MSDSs required for same product to satisfy different country & agency requirements
    • Resulting in confusion for end-users
    • Creating trade issues/hassles multinational companies
    • Costly & time consuming to manage
enter ghs
Enter GHS
  • GHS = Globally Harmonized System of Classification and Labelling of Chemicals
    • 1st edition approved in 2002 and published by UN in 2003
  • Result of international mandate (Chapter 19 of Agenda 21) from 1992 Rio Earth Summit (i.e.,UNCED)
    • Deemed to be single most important driving force behind the creation of GHS
    • Aimed to be completed GHS by 2000
    • A coordinating group chaired by OSHA was established to manage the work
  • Common & coherent global approach
    • To Classifying and Defining& Communicating Hazards
    • Provides Consistency/Harmonization to Labels and Safety Data Sheets
ghs at a glance
GHS At-A-Glance
  • GHS is Not…
    • A Regulation, Standard or Mandate
  • GHS is…
    • An Approach. It contains criteria, provisions, and explanatory text for harmonizing hazard communication
    • Adaptable by Country (and Agency)
      • Referred to as the “Building Block Approach”
        • Select parts of system that apply to existing regulations
        • Implementation consistent with requirements in place, or can use to create new requirements
why is ghs needed
Why is GHS Needed?

Better Trade

  • Compliance with multiple regulations is costly

and time-consuming

  • Regulatory burdens

make it difficult for companies to compete

internationally

osha alignment with ghs
OSHA Alignment with GHS
  • Revise HCS to Align with GHS
    • Maintain HCS framework
    • Enhance protection
    • Based on GHS Rev 3 (2009)
  • Major Changes
    • Chemical Classification
    • Safety Data Sheets (SDSs)
    • Labels
  • Compliance Enforcement – Phased In
    • Employees Trained on How to Read SDS/Label by Dec. 1, 2013
    • Manufacturers and Distributors Complete Reclassification and Produce Updated SDSs and Labels by June 1, 2015
      • Distributors may ship inventory with old SDS/Labels until Dec. 1, 2015
    • Full Employer Compliance Expected by June 1, 2016
    • Transitional Period can comply with old or new HCS/HazCom 2012
principle s of osha s alignment
Principle’s of OSHA’s Alignment
  • HCS requirements will not be reduced
  • Modifications made to support GHS
  • Not a total rewrite of the regulation
  • Bulk of tech requirements in Appendices
  • Versus regulatory text
  • Largely apply to chemical producers vs. users
  • OSHA estimates net savings for employers to be over $500 million/year
hcs hazcom 2012 appendicies
HCS / HazCom 2012 Appendicies
  • Appendix A: Health Hazard Criteria
  • Appendix B: Physical Hazard Criteria
  • Appendix C: Allocation of Label Elements
  • Appendix D: Safety Data Sheets
  • Appendix E: Definition of "Trade Secret”
  • Appendix F: Guidance for Hazard Classification Regarding Carcinogenicity
two most prevalent changes
Two Most Prevalent Changes
  • Hazard Classification Criteria
    • Health & Environmental Hazards
    • Physical Hazards
    • Mixtures
  • Hazard ‘Communication’
    • Labels
    • Safety Data Sheets
    • Training

OSHA is referring to revisedstandard as “HazCom 2012”

two most prevalent changes1
Two Most Prevalent Changes

OSHA added the definition of Classification to the revised standard:

“"Classification" means to identify the relevant data regarding the hazards of a chemical; review those data to ascertain the hazards associated with the chemical; and decide whether the chemical will be classified as hazardous according to the definition of hazardous chemical in this section.” 

two most prevalent changes2
Two Most Prevalent Changes

“In addition, classification for health and physical hazards includes the determination of the degree of hazard, where appropriate, by comparing the data with the criteria for health and physical hazards.”

2nd Key Component of the New Definition:

un s ghs hazard classifications
UN’s GHS Hazard Classifications
  • Health & Environmental
    • Acute Toxicity
    • Aspiration Toxicity
    • Skin Corrosion/Irritation
    • Serious Eye Damage/Eye Irritation
    • Respiratory or Skin Sensitization
    • Germ Cell Mutagenicity
    • Carcinogenicity
    • Reproductive Toxicity
    • Target Organ Systemic Toxicity – Single and Repeated Dose
    • Hazardous to the Aquatic Environment/Aquatic Toxicity
    • Hazardous to the Ozone Layer
  • Physical
    • Explosives
    • Flammable – Gases, Aerosols Liquids, Solids
    • Oxidizers– liquids, solids, gases
    • Self-Reactive Substances
    • Self-Heating Substances
    • Pyrophoric – liquids, solids
    • Organic Peroxides
    • Corrosive to Metals
    • Gases Under Pressure
    • Water-Activated Flammable Gases
hazcom 1994 vs hazcom 2012
HazCom 1994 vs HazCom 2012

HCS/HazCom 1994

  • Gases Under Pressure
    • Carcinogenicity

GHS Alignment/ HazCom 2012

  • Compressed Gases
  • Refrigerated Gases
  • Liquefied Gases
  • Dissolved Gases
  • Carcinogenicity
    • Category 1
      • 1A = Known
      • 1B = Probable
    • Category 2
      • Suspected

Note the numbering scheme: Lowerthe #, the more severe the hazard

un s ghs hazard classifications1
UN’s GHS Hazard Classifications
  • Health & Environmental
    • Acute Toxicity
    • Aspiration Toxicity
    • Skin Corrosion/Irritation
    • Serious Eye Damage/Eye Irritation
    • Respiratory or Skin Sensitization
    • Germ Cell Mutagenicity
    • Carcinogenicity
    • Reproductive Toxicity
    • Target Organ Systemic Toxicity – Single and Repeated Dose
    • Hazardous to the Aquatic Environment/Aquatic Toxicity
    • Hazardous to the Ozone Layer
  • Physical
    • Explosives
    • Flammable – Gases, Aerosols Liquids, Solids
    • Oxidizers– liquids, solids, gases
    • Self-Reactive Substances
    • Self-Heating Substances
    • Pyrophoric – liquids, solids
    • Organic Peroxides
    • Corrosive to Metals
    • Gases Under Pressure
    • Water-Activated Flammable Gases
under new osha definition
Under New OSHA Definition…
  • OSHA incorporated new elements into its revised definition of Hazardous Chemical
    • To include 3 classes of chemicals defined in its HCS that weren’t in GHS, Rev. 3
  • “Hazardous Chemical” means any chemical which is classified as a
    • Physical hazard; or
    • Health hazard; or
    • Simple asphyxiant; or
    • Combustible dust; or
    • Pyrophoric gas; or
    • Hazard Not Otherwise Classified(HNOC)
labels
Labels

Six Main Elements

  • Product/Chemical Identifier
labels1
Labels

Six Main Elements

  • Product/Chemical Identifier
  • Supplier Identifier
labels2
Labels

Six Main Elements

  • Product/Chemical Identifier
  • Supplier Identifier
  • Hazard Pictogram(s)*

* Standardized under GHS

label pictograms north america
Label Pictograms North America

Current North America (U.S. DOT/ Canada WHMIS) Systems

label pictograms dot and ghs
Label Pictograms – DOT and GHS

Transport Pictograms

GHS Pictograms

label pictograms
Label Pictograms

Flame

Exploding Bomb

Flame Over Circle

Flammable

Self Reactive

Pyrophoric

Self-Heating

Emits Flammable Gas

Organic Peroxides

Explosives

Self Reactive

Organic Peroxide

Oxidizers

Gas Cylinder

Skull and Crossbones

Corrosion

Skin Corrosion

Corrosive to Metals

Serious Damage to Eye

Gases Under

Pressure

Acute Toxicity

(Fatal or toxic)

Health Hazard

Exclamation Mark

Environment

(Not mandatory)

Carcinogenicity

Respiratory Sensitizer

Reproductive Toxicity

Target Organ Toxicity

Mutagenicity

Aspiration Toxicity

Skin & Eye Irritant

Dermal Sensitizer

Acute Toxicity (harmful)

Transient Target Organ Effects

Harmful to Ozone Layer (Not mandatory)

Environmental Toxicity

labels3
Labels

Six Main Elements

  • Product/Chemical Identifier
  • Supplier Identifier
  • Hazard Pictogram(s)*
  • Signal Word

* Standardized under GHS

labels4
Labels
  • Product/Chemical Identifier
  • Supplier Identifier
  • Hazard Pictogram(s)*
  • Signal Word
  • Hazard Statement(s)*

* Standardized under GHS

labels5
Labels
  • Product/Chemical Identifier
  • Supplier Identifier
  • Hazard Pictogram(s)*
  • Signal Word
  • Hazard Statement(s)*
  • Precautionary Information **

* Standardized under GHS

** Standardized under HCS

workplace labeling
Workplace Labeling
  • Employers May Continue to Use Current Workplace-Specific Labeling Systems
    • If they contain required information
    • If they are consistent with new classifications
  • Labels on Incoming Containers
    • Must not be removed or defaced
    • Unless immediately replaced
  • Workplace Labels
    • Must be prominently displayed
    • In English
    • Other languages permitted (additionally)
workplace labeling1
Workplace Labeling
  • Best practice - Whenever possible, replicate the shipping label
    • OSHA says your Workplace Labeling System + Employee Training should = at least the Same Level of Understanding as Shipped Label
  • OSHA says you can:
    • Use GHS shipped label
    • Use current system, so long as it :
      • Accounts for GHS changes
      • Doesn’t present conflicting information (with GHS changes)
      • When combined with your training, provides at least the same level of understanding as GHS shipped label
        • Includes use of alternative labeling systems like NFPA or HMIS
safety data sheets
Safety Data Sheets
  • Redefined as Safety Data Sheets (SDS)
    • GHS includes 16-part format
    • Essentially the ANSI Standard
  • Several Sections are not Mandatory
    • Sections 12-15
      • Ecological information
      • Disposal considerations
      • Transport information
      • Regulatory information
    • Outside of OSHA’s jurisdiction
  • New Appendix D
    • Details what is to be included in each section

=

sds headings
SDS – Headings
  • Identification
  • Hazard(s) Identification
  • Composition/Ingredient Information
  • First-Aid Measures
  • Fire-Fighting Measures
  • Accidental Release Measures
  • Handling and Storage
  • Exposure Control/ Personal Protection
  • Physical & Chemical Properties
  • Stability & Reactivity
  • Toxicological Information
  • Ecological Information
  • Disposal Considerations
  • Transport Information
  • Regulatory Information
  • Other Information
sds key changes
SDS – Key Changes
  • Section 2 – Hazard(s) Identification
    • GHS Classification
    • Pictograms
    • Signal Word
    • Hazard Statement
    • Precautionary Statement
sds to do
SDS – To Do
  • Make sure staff is on the lookout for new, GHS formatted SDSs – especially for chemicals you regularly receive
  • Talk to your chemical suppliers and ask about their plans to transition to GHS – the sooner switch over happens…the easier it will be on us all
  • Be in active preparation mode for GHS training. Have a plan and make sure employees are ready to read the GHS SDSs and labels
  • Don’t forget SARA obligations: update local and state emergency response agencies when new chemical hazard information becomes available
who s affected
Who’s Affected?

Pretty much everyone who “uses” hazardous chemicals has some responsibility… some more than others

  • Chemical Manufacturers have some work to do around re-classifying chemicals, and then re-authoring MSDSs, labels and warnings to make them GHS compliant
  • Resellers, Distributors, Importers get new MSDSs and labels ASAP & distribute to customers
  • Employers...
employers
Employers...
  • Inventory your on-site chemicals
  • Make sure you have a complete library of MSDSs
  • Stay current on OSHA
    • Federal
    • State & local
  • Keep an eye on GHS
    • Key dates
    • Impact on your plan
  • Have an HCS plan!
  • Maintain a checklist of key plan components
  • Review it annually, at least
  • Prepare yourself for the eventual MSDS churn
  • If you’re still using paper, consider transitioning to electronic system
  • Make sure your secondary labeling system is GHS compliant
  • Start developing a training plan for your employees
  • Request GHS compliant SDSs from chemical vendors
  • Ensure staff is on the lookout for SDSs with new shipments
  • Stay SARA compliant
penalties for noncompliance are very real
Penalties for Noncompliance Are Very Real
  • From 2009 – 2012 OSHA cited over 24,000 instances of HCS violations in workplaces across the United States
  • #2 on OSHA’s top 10 list of most frequently cited compliance standards for 2012

Source: www.OSHA.gov

costs add up quickly
Costs Add Up Quickly
  • Fines
  • Potential Risk & Liability
  • Downtime & Internal Disruption
  • Lost Revenues
  • Negative Press & Impact to Corporate Image
slide56

Questions

1.888.362.2007

www.MSDSonline.com

sales@MSDSonline.com

chaling@MSDSonline.com