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June 2013 Hazard Communication Standard Initially developed in 1983 to give employees a “right to know” Required a comprehensive hazard evaluation and communication process Chemical manufacturers and importers had to develop and provide container labels and Material Safety Data Sheets (MSDS). Employers with employees exposed to hazardous chemicals had to develop a hazard communication program including: • Labels • Access to MSDSs • Training on the workplace hazardous chemicals • The HCS established requirements for minimum information that had to be included on labels and MSDSs, but did not provide specific language to convey the information or a format in which to provide it. OSHA’s Final Ruling on GHS OSHA has updated its Hazard Communication Standard (HCS) to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Modifications will reduce costs and burdens while protecting employers and employees. Modifications include: • Revised criteria for classification of chemical hazards • Revised and standardized labeling requirements • A specified format for safety data sheets • Requirements for employee training on labels and safety data sheets OSHA’s GHS Implementation Deadlines 12/01/13: Employers must complete employee training on new label elements and SDS format 06/01/15: Chemical manufacturers, importers, distributors, and employers must comply with all modified provisions of the final rule 12/01/15: Distributors may not ship products labeled by manufacturers under the old system 06/01/16: Employers must update alternative workplace labeling and hazard communication programs as necessary, and provide additional worker training for new identified physical and health hazards Impact of GHS for U.S. Businesses • 880,000 hazardous chemicals are currently used in the U.S • Hazard Communication affects 43 million American workers in over 5 million workplaces • GHS will prevent 500 injuries/illnesses and 43 deaths per year, equaling a total of $250 million in reduced health and safety risks • Costs per year will total $201 million dollars to comply with revisions to the HCS • Future net benefits are estimated at $556 million dollars per year Hazard Communication Program Requirements 1. Written Hazard Communication Plan 2. Chemical Inventory 3. Labels & Warnings 4. Safety Data Sheets 5. Employee Training Container Label Changes HANDOUT Container Label Changes Changes to the HazCom Label Six elements of the GHS label format Label Element: Hazard Statements Statements assigned to a hazard class and category that describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of the hazards Label Element: Hazard Statements Notice the nature of the hazards: • FLAMMABLE GAS • INHALATION RISK • REPEATED EXPOSURE And the degree of the hazards: • EXTREMELY flammable gas • TOXIC if inhaled • DAMAGE to unborn child and organs Label Element: Precautionary Statements • Statements which describe recommended measures that should be taken to minimize or prevent adverse effects from exposure to a hazardous chemical or improper storage or handling • First aid measures are included in Precautionary Statements Label Element: Precautionary Statements PREVENTION Precautionary Statement(s): • Keep container tightly closed • Avoid breathing vapors RESPONSE Precautionary Statement(s): • Remove victim to fresh air… • Call a Poison Control Center… STORAGE Precautionary Statement: • Store in a well-ventilated place Benefits of GHS-formatted Labels • Past labels were inconsistent in terminology and visuals • Provide immediate visual reminders of hazards • Standardized signal words, visuals, and hazard statements • Pictograms reinforce messages presented in text while enhancing communication for low-literacy users • Precautionary statements provide useful steps to protect from and prevent chemical-related injuries and illnesses Example of Multi-Language Label GHS Pictograms HANDOUT GHS Pictograms GHS Pictograms – Health Hazards GHS Pictograms – Physical Hazards GHS Pictograms Secondary Containers Containers used for storage or transfer of chemicals other than the original manufacturer’s container These may include: • Portable or working containers • Storage containers that are created for distribution of smaller amounts of the chemical Do I need to label it? YES! The only time a hazardous chemical does NOT need to be labeled is when the container is intended only for the immediate use of the employee who performs the transfer What does a Secondary Container Label need to display? • The same information on the manufacturer’s label, or • Words, pictures, symbols or a combination thereof which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical Safety Data Sheets HANDOUT Safety Data Sheets Previously known as Material Data Safety Sheets (MSDS), they will now be referred to as Safety Data Sheets (SDS) GHS standardizes the order of SDS information for ease of use of employees along with improved accuracy of the information presented The number of sections has been increased to 16 sections Safety Data Sheets Format 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. IDENTIFICATION HAZARDS IDENTIFICATION COMPOSITION/INFORMATION ON INGREDIENTS FIRST AID MEASURES FIREFIGHTING MEASURES ACCIDENTAL RELEASE MEASURES HANDLING AND STORAGE EXPOSURE CONTROLS/PERSONAL PROTECTION PHYSICAL AND CHEMICAL PROPERTIES STABILITY AND REACTIVITY TOXICOLOGICAL INFORMATION ECOLOGICAL INFORMATION DISPOSAL CONSIDERATIONS TRANSPORT INFORMATION REGULATORY INFORMATION OTHER INFORMATION INCLUDING INFORMATION ON PREPARATION AND REVISION OF THE SDS MSDS/SDS Maintenance • Inventory hazardous chemicals in the warehouse, yard, and office. Don’t forget fuels, toner, etc. • Do you have a current MSDS/SDS for each hazardous chemical? Check with the manufacturer. • Remove/Replace duplicate and obsolete MSDS/SDS. • Are MSDS/SDS in HazCom Notebook(s) and readily accessible to employees? • As the June 1, 2015 deadline nears, you may have to contact chemical manufacturers, importers, and distributors to receive SDS not already received . OSHA HazCom/GHS Responsibilities Chemical manufacturers and importers • • • Hazard Re-Classification Label Changes Safety Data Sheets (SDS) Changes and Distribution Employers • • • • • • Ensure all chemicals in the workplace are clearly and properly labeled Update secondary container labels Ensure new SDS are available to all employees as they are received Distribute SDS to customers when chemicals are first shipped to them after receipt of new/revised SDS Train Employees Update HazCom programs as necessary Questions? Learning Exercise