Revised OSHA Hazard Communication Standard: Implications and Changes
Today's session highlights the revised OSHA Hazard Communication Standard (HCS) and its implications for chemical manufacturers, distributors, and cleaning service providers. The presentation covers the background of the HCS, the impact of the Globally Harmonized System (GHS) revisions, what remains the same under the GHS revisions, and what has changed in tactics such as hazard classification, SDS redrafting, labeling, and more. It delves into the obligations for chemical manufacturers and distributors, detailing the need to reclassify products, redraft SDSs, and redo labels by specific deadlines. Stay informed about the significant shifts in chemical hazard communication for a safer workplace environment.
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Presentation Transcript
Bill Balek ISSA July 31, 2013
Todays Session Employee Education and Training Revised OSHA Hazard Communication Standard Due Dec. 1, 2013 Background March 20, 2012: OSHA issues final rule GHS revisions to Hazard Communication Standard
Background OSHA HCS Governs: Chemicals MSDSs Labels Employee education and training Purpose: Avoid chemical injury and illnesses
Background 1985: OSHA issues HCS Labeling, MSDS for hazardous chemicals 2001: Globally Harmonized System of Classification and Labeling of Chemicals (GHS) UN members agree to adopt GHS by 2008 2012: GHS Revisions to HCS
What remains the same under GHS Revs? Basic structure Manufacturers: Classify chemicals and provide SDS, labels to downstream customers Distributors: Pass SDS and labels downstream Employers: Employee education and training Avoid chemical injuries and illnesses
Whats changed? Tactics. Classification of hazards (Manufacturer) SDS: redraft to comport with new format, pictograms, etc. (Manufacturer) Labeling (Manufacturer) More prescriptive, uniform language Pictograms
Implications for Cleaning industry Chemical Manufacturers Distributors Cleaning Service Providers
Implications for Chemical Manufacturers Obligations that run to downstream customers Re-classify products Re-draft SDSs Re-do labels June 1, 2015
Implications for Distributors Obligations that run to downstream customers Send new GHS SDS (June 1, 2015) Ship products with new GHS labels (Dec. 1, 2015)
Implications for Employers Employers: Manufacturers, Distributors, Cleaning Service Providers Employee education and training New label elements New SDS format Dec. 1, 2013
New Labeling Elements Effective June 1, 2015 Distributors Dec. 1, 2015 Permissible to comply earlier
Safety Data Sheets (SDS) Formerly MSDS New 16 section uniform format Effective June 1, 2015 Permissible to comply earlier
Workers may see GHS labels, SDS soon OSHA requires employee training New label elements New SDS format Dec. 1, 2013 Ensure workers have info to protect themselves Understand GHS labels and SDS
Product identifier Signal word Hazard statement Pictograms Precautionary statement(s) Name, address, telephone number of manufacturer or other responsible party
Signal word Hazard statement Pictograms Harmonized label elements Based on hazard class and hazard category In general, manufacturer has no discretion
Product identifier Name of product Same as on SDS Signal word Indicates severity of hazard Danger: more severe hazards Warning: less severe hazards Only one signal word on the label Not all hazards have signal words
Hazard statement Describes the nature of the hazard Causes skin irritation Flammable liquid and vapor All applicable hazard statements must be on label Uniform (mandatory Appendix C)
Pictograms Images that communicates the hazard Square on point Black hazard symbol White background Red border Red border minus hazard symbol NOT allowed
Skin corrosion, burns Eye damage Corrosive to metals
Flammable Pyrophorics Self-heating Emits flammable gas Self-reactive Organic peroxides
Oxidizer Gases under pressure
Carcinogen Mutagenicity Reproductive toxicity Respiratory Sensitizer Target organ toxicity Aspiration toxicity
Explosives Self-reactives Organic peroxides Acute toxicity (fatal or toxic)
Irritant (skin, eye) Skin sensitizer Acute toxicity Narcotic effects Respiratory tract irritant Hazardous to ozone layer Aquatic toxicity Non-mandatory
Precautionary Statements Recommended measures to prevent or minimize adverse effects from exposure , improper storage or handling What to do to prevent harmful exposure Wash thoroughly after handling Wear protective gloves What to do if there is harmful exposure If eye irritation persists, get medical advice
Name, address, telephone number of manufacturer or other responsible party Address City and state sufficient Telephone number New requirement
Pictogram Product Identifier Signal Word XYZ Cleaner Warning XYZ Manufacturing Co. Chicago, IL 312.123.4567 Causes serious eye irritation Hazard Statement Wash hands thoroughly after handling. Wear eye protection. Store in a cool dry place. First Aid If in eyes, rinse cautiously with water for several minutes. Remove contact lenses, if present, and easy to do. Continue rinsing. If eye irritation persists: get medical attention. Manufacturer Precautionary Statement
Make sure employees know How to go from label to SDS How to use label to Properly store product Work with product safely Avoid harmful exposure What to do in event of harmful exposure Where product has multiple hazards Multiple pictograms, hazard statements
Standardized 16-section format SDS must be presented in a consistent order Sec. 1: Identification Product identifier used on label Recommended use of the chemical Name, address and telephone number of manufacturer, importer or other responsible party Emergency phone number
Standardized 16-section format Sec. 2: Hazard identification Hazard class, and category (i.e., flammable liquid, category 4) Label elements: Signal word (i.e., Warning) Hazard statement (i.e., combustible liquid) Pictograms (none for flammable liquid, cat. 4) Precautionary statement Consistent with label / Heart of SDS
Standardized 16-section format Sec. 3: Composition/information on ingredients Information on chemical ingredients, trade secrets Sec. 4: First-aid measures Description of measures based on route of exposure Immediate medical treatment Sec. 5: Fire fighting measures Suitable and unsuitable extinguishing media Special hazards presented by the chemical in fire
Standardized 16-section format Sec. 6: Accidental release measures Personal precautions, emergency procedures Sec. 7: Handling and storage Precautions for safe handling and storage Any incompatibilities Sec. 8: Exposure controls / personal protection OSHA PELs, TLVs Appropriate engineering controls (ventilation PPE
Standardized 16-section format Sec. 9: Physical and chemical properties Appearance, pH, odor, flash point, vapor pressure, etc. Sec. 10: Stability and reactivity Chemical stability, possibility of hazardous reactions Conditions to avoid, incompatible materials Sec. 11: Toxicological information Routes of exposure, related symptoms, acute and chronic effects
Standardized 16-section format SDS must contain sections 12-15, but OSHA will not enforce the content for these Sections Sec. 12: Ecological information Sec. 13: Disposal considerations Sec. 14: Transportation information Sec. 15: Regulatory information Sec. 16: Date of preparation, last revision
Info must be presented in manner workers can understand Non-english speaking workers Illiterate Recommend: Keep record of employees trained Sign in log Training materials used Tests
If you would like a certificate indicating you have been trained consistent with the GHS HazCom Training requirements Email: bill@issa.com Subject Line: CERTIFICATE Short Test Upon passing test, certificate will be issued
ISSA Resources Detailed Summary: www.issa.com/ghshcs Manufacturers: Formulator Webinar Series Reclassification, SDS, Labels Tracy@issa.com: Formulator Webinar Employee Education and Training (Dec. 1, 2013) Webinar: July 31 Online training: www.issa.com/ghs Resources: www.issa.com/ghstraining
Questions??? Bill Balek, ISSA bill@issa.com 800.225.4772
