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GLOBALLY HARMONIZED SYSTEM for HAZARD COMMUNICATION. David Wallace, CIH Sr. Lecturer, Utah State University Nevada Local Section, AIHA March 9, 2011. Outline. GHS overview OSHA’s GHS activity Proposed changes to the Hazard Communication Standard Current status of the proposed standard

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globally harmonized system for hazard communication

GLOBALLY HARMONIZED SYSTEM for HAZARD COMMUNICATION

David Wallace, CIH

Sr. Lecturer, Utah State University

Nevada Local Section, AIHA

March 9, 2011

outline
Outline
  • GHS overview
  • OSHA’s GHS activity
  • Proposed changes to the Hazard Communication Standard
  • Current status of the proposed standard
  • Impact on Safety professionals
introduction
Introduction
  • In 1985, one of my jobs as a “young” industrial hygiene 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!
introduction1
Introduction
  • AIHA online GHS course, if you want to learn more!
ghs overview
GHS Overview
  • “Globally Harmonized System Of Classification And Labeling Of Chemicals”
    • United Nations guidance for a uniform (harmonized) hazard communication system
      • Initiated at the 1992 United Nations Conference on Environment and Development (UNCED)
    • 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

GHS “Purple Book”

  • 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.
    • Guide to the GHS (OSHA)
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
flammability example1
Flammability Example
  • OSHA letter of interpretation, July 14, 2010
    • Re: The definitions of combustible and flammable liquids under 29 CFR 1926 and 29 CFR 1910. 
    • Question: Why are the definitions for combustible liquids and flammable liquids different under OSHA's construction and general industry standards? 
    • Answer: The definitions in the two standards are different because the definitions were adopted from different sources. OSHA is currently addressing these definitions in the Hazard Communication rulemaking. [GHS}
    • http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27488
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 (16)

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 (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

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) with red border
      • Examples:
ghs hazard communication1
GHS Hazard Communication
  • Labels (cont.)
    • Nine symbols
      • Includes “Environment”
ghs hazard communication2
GHS Hazard Communication
  • Labels (cont.)
    • Signal Words
      • “Danger” or “Warning”
    • Hazard Statements
      • Example: “Toxic if swallowed”
    • Other
      • Precautions, identification, supplier, supplemental
ghs hazard communication3
GHS Hazard Communication
  • Labels (cont.)
    • GHS Label Elements for Flammable Liquids
ghs hazard communication4
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

24

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

25

osha and the ghs
OSHA and the GHS
  • Rulemaking Steps
    • Advance Notice of Proposed Rulemaking, ANPR
      • Sept. 12, 2006
    • Notice of Proposed Rulemaking
      • Sept. 30, 2009
      • Public Comment Period ended Dec. 29, 2009
      • Public Hearings
        • Washington, Pittsburgh and Los Angeles
        • March and April, 2010
      • Post-hearing Comment Period ended June 1, 2010
    • Final Standard
      • Probably by late 2011, according to OSHA staff
    • Phase-in Period for Compliance
      • 2-3 years (as proposed)
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 must 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
    • Side-by-side comparison (OSHA)
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 Interpretation 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.
  • Public Hearings ended April 13, 2010
  • Record closed June 1, 2010 (877 items)
comments on the proposed rule1
Comments on the proposed rule
  • Maureen Ruskin, director of OSHA's Office of Chemical Hazards, at GHS Round Table, 5/24/2010, AIHCE, Denver, Co
    • Vast majority of comments support OSHA
    • OSHA should adopt EU reporting limits for chronic hazards
    • Create “hazards not otherwise classified” category
    • Support and criticism of proposal to drop TLVs
    • Updating labels within 30 days may not be feasible
    • OSHA may have underestimated cost of red border
    • Mixed support for adoption of GHS hazard statements
    • Disagreement about implementation dates
    • OSHA should provide more information for training
comments on the proposed rule2
Comments on the proposed rule
  • OSHA’s update (cont.)
    • Some believe OSHA will create confusion with changes to flammable/combustible liquid classification, yet others agreed with OSHA
    • OSHA should review safety standards to avoid conflicts
    • Concerns over carcinogen notation changes in the health standards
    • Concerns about conflict or confusion regarding EPA/DOT/NFPA
    • OSHA underestimated costs
    • Very little support for OSHA’s proposed alternatives
    • How will OSHA respond after UN updates GHS?
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

TLV and REL 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
aiha s comment
“AIHA supports the proposed revision of the HCS and believes it will result in better hazard recognition and safer use of chemicals in the workplace.”

AIHA’s generally supports OSHA:

Proposed hazard classifications are OK

OSHA should require red borders on labels

TLVs , WEELs and other exposure limits should be listed on data sheets

OSHA should include a hazard category for combustible dust

Training should not be delayed

AIHA also submitted a post-hearing comment, April 29, 2010 to answer OSHA questions

AIHA’s comment
osha s schedule
OSHA’s Schedule
  • Record closed June 1
  • Tasks:
    • Analyze information in the record
    • Prepare the final rule and update the analyses of the record
    • Submit rule for administrative review
    • OSHA, DOL, OMB
  • This is high priority for OSHA
    • Expect final standard about 1 ½ years (?)
recent ghs activity
Recent GHS activity
  • United Nations Subcommittee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (UNSCEGHS), Dec. 7-9, 2010, in Geneva
  • OSHA hosted an open informal public meeting of the U.S. Interagency GHS Coordinating Group, Nov. 20, 2010.
    • To provide interested parties with an update on GHS issues in preparation for the UN meeting
    • http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=21809
osha s schedule1
OSHA’s Schedule
  • Dr. David Michaels, Assistant Secretary of Labor for OSHA
    • June 16, 2010 at the Baltimore ASSE conference:

the Global Harmonized System standard –a “non-controversial rule” – has received good comments and is moving along on target

      • Source: Occupational Health and Safety online magazine
slide40

OSHA’s Fall 2010 Regulatory Agenda, http://www.dol.gov/osha/regs/unifiedagenda/fall2010/1218-AC20.htm

commercial ghs services
Commercial GHS services
  • Commercial Hazard Communication and MSDS/SDS authoring services should be “ready” for GHS
    • Required for international trade
    • Preparing for domestic market
  • Examples:
    • http://3ecompany.com/solutions/ghs-solutions/
    • http://www.sitehawk.com/ghs_home.html
ghs in the commercial news
GHS in the commercial news
  • Industry Week
    • How to Convert to the Globally Harmonized System of Chemical Classification
  • EHS Today
    • GHS: The Power of One
  • OH&S
    • Major GHS Progress This Year
    • OSHA's GHS Leader Sees Final Rule in 18 Months
    • Global Harmonization — A Catalyst for Safety
    • OSHA, GHS, and Your MSDSs and Labels
    • A Picture is Worth a Thousand Words
    • OSHA Finally Brings GHS to America
impact on safety and ih professionals
Impact on Safety and IH Professionals
  • Become familiar with the new system
    • May want to wait until the OSHA rule is “final”
  • Collect new SDSs as provided by suppliers and incorporate them into the existing MSDS system (or use a commercial service)
  • Get new GHS labels for “shipped containers”
    • Employers can use other systems for workplace labeling
  • Train employees about new labels and SDS
impact on chemical manufacturers and distributors
Impact on Chemical Manufacturers and Distributors
  • Prepare and use new GHS compatible labels
  • Prepare and distribute new GHS compatible Safety Data Sheets
  • Commercial “authoring” firms are ready and willing to help
ghs resources
GHS 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/[this site will be replaced with the Federal Digital System, http://www.gpo.gov/fdsys/]
  • OSHA comments
    • Docket No. OSHA-H022K- 2006-0062 at http://www.regulations.gov
      • Nearly 900 items!