© 2013 360training.com © 2013 360training.com Marie Athey, OHST GHS and Hazardous Communication Compliance Are You Ready to Meet the 12/1/2013 Deadline?
May 13, 2015
© 2013 360training.com© 2013 360training.com
Marie Athey, OHST
GHS and Hazardous Communication Compliance
Are You Ready to Meet the 12/1/2013 Deadline?
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Marie Athey, OHST
• Director of EHS Product Line Management at 360training.com• Degreed with over 15 years of EHS experience having worked
for various US companies in Construction and General Industry.• Training certifications:
– ANSI ASTM CAP– OHST designated by BCSP– OSHA 500 and 501 Instructor 10/30 hour classes – Competent Person Trainer- Trenching / Excavation– Competent Person Trainer – Fall Protection– Competent Person Trainer- Scaffold – HAZWOPER Instructor 1910.120– First Aid/CPR /AED Instructor- Medic First Aid– Approved Professional Source- State of Texas – Texas Department of
Insurance #1952
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Objectives
• Understand the Scope of Globally Harmonized System (GHS) -15 Minutes– What is it?– Who is affected?
• Significant Changes - 30 Minutes– Phases of implementation– Training topics– Labels and SDS– Free resources available
• Are You in Compliance? -15 Minutes– Written Hazard Communication Program– Training solutions
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GHS
Ready to Comply?
HAZARDOUS COMMUNICATION STANDARD
RIGHT TO KNOW 29CFR 1910.1200
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Some Interesting Facts about Hazard Communication Standard and Globally Harmonized System
• Over 50 Million American workers are exposed to hazardous chemicals in their workplaces.
• Over 5 Million Businesses will be impacted by the new GHS requirements for labeling and SDS.
• HCS covers some 650,000 hazardous chemical products found in over five million establishments.
• In 2012, OSHA issued 4,696 citations for Hazard Communication (29 CFR 1910.1200) violations (mainly due to lack of training, labeling fail, access to MSDSs and lacking correct MSDSs).
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Globally Harmonized System- What is it?
• OSHA revised its Hazard Communication Standard (HCS) March 2012
• Aligns with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS)
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Globally Harmonized System (GHS)
• Nations recognized chemical hazards must be classified and labeled under a universally understood communications system to avoid risks to human health and the environment.
• Nations throughout the world agreed to harmonize chemical hazard communications under a system developed by the United Nations (UN) and the International Labor Organization (ILO).
• Globally Harmonized System of Classification and Labeling of Chemicals (GHS), adopted by consensus in 2003 by the United Nations Economic and Social Council.
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Phases of Implementation
By December 1, 2013, Employees must be trained on new labeling and SDSTo help companies
comply with the revised standard, OSHA is phasing in the specific requirements over several years (December 1, 2013 to June 1, 2016).
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Two Significant Changes
Training Requirement:
New labeling elements
Training Requirement:
Standardized format for Safety Data Sheets (SDSs)
Improve worker understanding of the hazards
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Label Elements
Training Requirement
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OSHA Minimum Required Training Topics
Training tip from Dr. Michaels: Label Elements
1. Product Identifier
2. Signal Word
3. Pictogram
4. Hazard Statement
5. Precautionary Statements
6. Name, address, phone of manufacturer, distributor, importer
OSHA requires employers: (with all training)
Present information in a manner and language that their employees can understand.
If employers customarily need to communicate work instructions or other workplace information to employees in a language other than English, they will also need to provide safety and health training to employees in the same manner.
Similarly, if the employee’s vocabulary is limited, the training must account for that limitation.
By the same token, if employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation.
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Required Training- Labels
Label Elements
1. Product Identifier
2. Signal Word
3. Pictogram
4. Hazard Statement
5. Precautionary Statements
6. Name, address, phone of manufacturer, distributor, importer
Do you recognize the six elements?
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Label Elements
1. Product Identifier• Chemical Name• Code number or batch number• Manufacturer, importer or distributor can decide the
appropriate product identifier • Product identifier must be both on the label and in
Section 1 of the SDS (Identification)
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Label Elements
2. Signal Word– Used to indicate the relative level of severity of hazard
and alert the reader to a potential hazard on the label. – Two Words: “Danger” and “Warning.”– “Danger” is used for more severe hazards.– “Warning” is used for less severe hazards.– There will only be one signal word on the label no
matter how many hazards a chemical may have.– If one of the hazards warrants a “Danger” signal
word and another warrants the signal word “Warning,” then only “Danger” should appear on the label.
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Label Elements
Examples:
3. Pictogram:(hazard pictograms) with red border
*A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label.
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Pictograms
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Label Element:
4. Hazard Statement
• Describe the nature of the hazard(s) of a chemical.
For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed
through the skin.” • All of the applicable hazard statements must appear on the label.• Hazard statements may be combined where appropriate to reduce
redundancies and improve readability.• Hazard statements are specific to the hazard classification
categories.• Chemical users should always see the same statement for the same
hazards, no matter what the chemical is or who produces it.
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Label Elements
5. Precautionary Statement– Phrase that describes recommended measures that should be
taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.
Example: Labels give workers information on correct storage of the chemical or exposure effects.
Example: Information on the label might be used to quickly locate information on first aid when needed by employees or emergency personnel.
6. Name, address, phone of manufacturer, distributor, importer
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How the elements work together on a label
• Where a chemical has multiple hazards, different pictograms are used to identify the various hazards.
• Employees should expect to see the appropriate pictogram for the corresponding hazard class.
• When there are similar precautionary statements, the one providing the most protective information will be included on the label.
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Safety Data Sheets (SDS)
Training Requirement
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Safety Data Sheet (SDS)
• As of June 1, 2015, the HCS will require new SDSs to be in a uniform format, and include the section numbers, the headings, and associated information.
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SDS Training Requirements
Training on the format of the SDS must include information on:
1. Standardized 16-section format, including the type of information found in the various sections
Example- the employee should be instructed that with the new format, Section 8 (Exposure Controls/Personal Protection) will always contain information about exposure limits, engineering controls and ways to protect yourself, including personal protective equipment.
2. How the information on the label is related to the SDS
Example- explain that the precautionary statements would be the same on the label and on the SDS.
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New Safety Data Sheet (SDS) Format
• Section 1, Identification• Section 2, Hazard(s)
Identification• Section 3,
Composition/Information on Ingredients
• Section 4, First Aid Measures• Section 5, Fire Fighting
Measures• Section 6, Accidental Release
Measures• Section 7, Handling and Storage• Section 8, Exposure Controls/
Personal Protection
• Section 9, Physical and Chemical Properties
• Section 10. Stability and Reactivity
• Section 11, Toxicological Information
• Section 12, Ecological Information
• Section 13, Disposal Considerations
• Section 14. Transport Information• Section 15, Regulatory
Information• Section 16, Other Information
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Safety Data Sheets (SDS)
• Section 1, Identification– includes product
identifier, manufacturer or distributor name, address, phone number; emergency phone number, recommended use, restrictions on use.
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Safety Data Sheets (SDS)
• Section 2, Hazard(s) Identification– includes all hazards
regarding the chemical; required label elements.
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Safety Data Sheets (SDS)
• Section 3, Composition/ Information on Ingredients– includes information
on chemical ingredients; trade secret claims.
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Safety Data Sheets (SDS)
• Section 4, First aid Measures– includes important
symptoms/effects, acute, delayed; required treatment.
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Safety Data Sheets (SDS)
• Section 5, Fire Fighting Measures– lists suitable extinguishing techniques, equipment; chemical
hazards from fire.
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Safety Data Sheets (SDS)
• Section 6, Accidental Release Measures– lists emergency
procedures, protective equipment, proper methods of containment and cleanup.
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Safety Data Sheets (SDS)
• Section 7, Handling and Storage– lists precautions for
safe handling and storage, including incompatibilities.
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Safety Data Sheets (SDS)
• Section 8, Exposure Controls/ Personal Protection– lists OSHA’s
Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
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Safety Data Sheets (SDS)
• Section 9, Physical and Chemical Properties– lists the chemical’s
characteristics.
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Safety Data Sheets (SDS)
• Section 10, Stability and Reactivity– lists chemical stability
and possibility of hazardous reactions.
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Safety Data Sheets (SDS)
• Section 11, Toxicological Information– includes routes of
exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
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Safety Data Sheets (SDS)
• Section 12, Ecological information*• Section 13, Disposal considerations*• Section 14, Transport information*• Section 15, Regulatory information*
Note: Since other Agencies regulate this information,
OSHA will not be enforcing Sections 12 through 15
(29 CFR 1910.1200(g)(2)).
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Safety Data Sheets (SDS)
• Sections 12 and 13• Examples
SDS Vs. MSDS
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Safety Data Sheets (SDS)
• Section 14• Example:
SDS Vs. MSDS
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Safety Data Sheets (SDS)
• Section 15• Example:
SDS Vs. MSDS
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Safety Data Sheets (SDS)
• Section 16, Other Information– includes the date of
preparation or last revision.
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Free Supplemental Resources
• OSHA Fact Sheet – Training Requirements for the Revised Hazard Communication Standard– https://www.osha.gov/Publications/OSHA3642.pdf
• Quick Card SDS– https://www.osha.gov/Publications/OSHA3493QuickCardSafety
DataSheet.pdf
• Quick Card Labels– https://www.osha.gov/Publications/HazComm_QuickCard_Label
s.html
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Hazardous Communication
Compliance
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Checklist to Comply with HCS
Obtain a copy of the rule. (29CFR1910.1200) osha.gov Read and understand the requirements. Assign responsibility for tasks. Prepare an inventory of chemicals. Ensure containers are labeled. Obtain SDS for each chemical. Prepare Hazardous Communication written program. Make SDSs available to workers. Conduct training for workers upon hire, annually, change. Establish procedures to maintain current program. Establish procedures to evaluate effectiveness.
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• GHS and OSHA Hazardous Communication demo