HOW TO COMPLY WITH THE NEW GHS HAZCOM PROGRAM INTRODUCTION

Transcription

1 HOW TO COMPLY WITH THE NEW GHS HAZCOM PROGRAM INTRODUCTION There is a lt f infrmatin abut the new Hazard Cmmunicatins prgram that s changing the way rganizatins cmply with the new rules. This prgram is an explanatin f hw t cmply, withut changing yur entire HAZCOM prgram. The Glbally Harmnized System (GHS) is an internatinal apprach t hazard cmmunicatin, prviding agreed criteria fr classificatin f chemical hazards, and a standardized apprach t label elements and safety data sheets. It is based n majr existing systems arund the wrld, including OSHA's Hazard Cmmunicatin Standard and the chemical classificatin and labeling systems f ther US agencies. The result f this negtiatin prcess is the United Natins' dcument entitled "Glbally Harmnized System f Classificatin and Labeling f Chemicals," cmmnly referred t as The Purple Bk. OSHA has mdified the Hazard Cmmunicatin Standard (HCS) t adpt the GHS t imprve safety and health f wrkers thrugh mre effective cmmunicatins n chemical hazards. The GHS prvides a standardized apprach, including detailed criteria fr determining what hazardus effects a chemical pses, as well as standardized label elements assigned by hazard class and categry. This will enhance bth emplyer and wrker cmprehensin f the hazards, which will help t ensure apprpriate handling and safe use f wrkplace chemicals. In additin, the safety data sheet requirements establish an rder f infrmatin that is standardized. The harmnized frmat f the safety data sheets will enable emplyers, wrkers, health prfessinals, and emergency respnders t access the infrmatin mre efficiently and effectively, thus increasing their utility. Adptin f the GHS in the US and arund the wrld will als help t imprve infrmatin received frm ther cuntries since the US is bth a majr imprter and 1

2 exprter f chemicals, American wrkers ften see labels and safety data sheets frm ther cuntries. The diverse and smetimes cnflicting natinal and internatinal requirements can create cnfusin amng thse wh seek t use hazard infrmatin effectively. During the phase-in perid, emplyers wuld be required t be in cmpliance with either the existing HCS r the revised HCS, r bth. OSHA recgnizes that hazard cmmunicatin prgrams will g thrugh a perid f time where labels and SDSs under bth standards will be present in the wrkplace. This will be cnsidered acceptable, and emplyers are nt required t maintain tw sets f labels and SDSs fr cmpliance purpses. CHANGES TO HAZCOM OSHA is requiring that emplyees are trained n the new label elements, such as pictgrams and signal wrds and the new SDS frmat by December While many cuntries are in varius stages f implementing the GHS, OSHA believes that it is pssible that American wrkplaces may begin t receive labels and SDSs that are cnsistent with the GHS shrtly after publicatin. Thus, making it imprtant t ensure that when emplyees begin t see the new labels and SDSs in their wrkplaces, they will be familiar with them, understand hw t use them, and access the infrmatin effectively. The three majr areas f change are in hazard classificatin, labels, and safety data sheets. Hazard classificatin: The definitins f hazard have been changed t prvide specific criteria fr classificatin f health and physical hazards, as well as classificatin f mixtures. These specific criteria will help t ensure that evaluatins f hazardus effects are cnsistent acrss manufacturers, and that labels and safety data sheets are mre accurate as a result. Labels: Chemical manufacturers and imprters will be required t prvide a label that includes a harmnized signal wrd, pictgram, and hazard statement fr each hazard class and categry. Precautinary statements must als be prvided. 2

3 Safety Data Sheets: Will nw have a specified 16-sectin frmat. The revised Hazard Cmmunicatin Standard (HCS) is a mdificatin t the existing standard. The parts f the standard that did nt relate t the GHS remained largely unchanged. There have been sme mdificatins t terminlgy in rder t align the revised HCS with language used in the GHS. Fr example, the term "hazard determinatin" has been changed t "hazard classificatin" and "material safety data sheet" was changed t "safety data sheet." HAZARD CLASSIFICATION Under bth the current Hazard Cmmunicatin Standard (HCS) and the revised HCS, an evaluatin f chemical hazards must be perfrmed cnsidering the available scientific evidence cncerning such hazards. The revised HCS has specific criteria fr each health and physical hazard, alng with detailed instructins fr hazard evaluatin and determinatins as t whether mixtures r substances are cvered. It als establishes bth hazard classes and hazard categries fr mst f the effects; the classes are divided int categries that reflect the relative severity f the effect. The current HCS des nt include categries fr mst f the health hazards cvered, s this new apprach prvides additinal infrmatin that can be related t the apprpriate respnse t address the hazard. LABELS Under the current Hazard Cmmunicatin Standard (HCS), the label preparer must prvide the identity f the chemical, and the apprpriate hazard warnings. This may be dne in a variety f ways, and the methd t cnvey the infrmatin is left t the preparer. Under the revised HCS, nce the hazard classificatin is cmpleted, the standard specifies what infrmatin is t be prvided fr each hazard class and categry. Labels will require the fllwing elements: Pictgram: a symbl plus ther graphic elements, such as a brder, backgrund pattern, r clr that is intended t cnvey specific infrmatin abut the hazards f a chemical. Each pictgram cnsists f a different symbl n a white 3

4 backgrund within a red square frame set n a pint (i.e. a red diamnd). There are nine pictgrams under the GHS. Hwever, nly eight pictgrams are required under the HCS. Signal wrds: a single wrd used t indicate the relative level f severity f hazard and alert the reader t a ptential hazard n the label. The signal wrds used are "danger" and "warning." "Danger" is used fr the mre severe hazards, while "warning" is used fr less severe hazards. Hazard Statement: a statement assigned t a hazard class and categry that describes the nature f the hazard(s) f a chemical, including, where apprpriate, the degree f hazard. Precautinary Statement: a phrase that describes recmmended measures t be taken t minimize r prevent adverse effects resulting frm expsure t a hazardus chemical, r imprper strage r handling f a hazardus chemical. There are nine pictgrams under the GHS t cnvey the health, physical and envirnmental hazards. The final Hazard Cmmunicatin Standard (HCS) requires eight f these pictgrams, the exceptin being the envirnmental pictgram, as envirnmental hazards are nt within OSHA's jurisdictin. A quick lk at the hazard pictgrams and their crrespnding hazards Health Hazard (flame) Carcingen Mutagenicity Reprductive Txicity Respiratry Sensitizer Target Organ Txicity Aspiratin Txicity Flammables Pyrphrics Self-Heating Emits Flammable Gas Self-Reactives Organic Perxides 4

5 Irritant (skin and eye) Skin Sensitizer Acute Txicity (harmful) Narctic Effects Respiratry Tract Irritant Hazardus t Ozne Layer Crrsin (Explding Bmb) Gases under Pressure Skin Crrsin/ burns Eye Damage Crrsive t Metals Explsives Self-Reactives Organic Perxides Envirnment (Flame ver Circle) (Nn Mandatry) Skull and Crssbnes Oxidizers Aquatic Txicity Acute Txicity (fatal r txic) MORE ON PICTOGRAMS Under the revised Hazard Cmmunicatin Standard (HCS), pictgrams must have red brders. OSHA believes that the use f the red frame will increase recgnitin and 5

6 cmprehensibility. Therefre, the red frame is required regardless f whether the shipment is dmestic r internatinal. The revised Hazard Cmmunicatin Standard (HCS) requires that all red brders printed n the label have a symbl printed inside it. Emplyers may chse t label wrkplace cntainers either with the same label that wuld be n shipped cntainers fr the chemical under the revised rule, r with label alternatives that meet the requirements fr the standard. Alternative labeling systems such as the Natinal Fire Prtectin Assciatin (NFPA) 704 Hazard Rating and the Hazardus Material Infrmatin System (HMIS) are permitted fr wrkplace cntainers. Hwever, the infrmatin supplied n these labels must be cnsistent with the revised HCS, such as n cnflicting hazard warnings r pictgrams. NEW SAFETY DATA SHEETS The infrmatin required n the safety data sheet (SDS) will remain essentially the same as that in the current standard. The current Hazard Cmmunicatin Standard (HCS) indicates what infrmatin has t be included n an SDS but des nt specify a frmat fr presentatin r rder f infrmatin. The revised HCS requires that the infrmatin n the SDS is presented using cnsistent headings in a specified sequence. The SDS frmat is the same as the ANSI standard frmat which is widely used in the U.S. and is already familiar t many emplyees. The frmat f the 16-sectin SDS shuld include the fllwing sectins: Sectin 1. Identificatin Sectin 2. Hazard(s) identificatin Sectin 3. Cmpsitin/infrmatin n ingredients Sectin 4. First-Aid measures Sectin 5. Fire-fighting measures Sectin 6. Accidental release measures Sectin 7. Handling and strage 6

7 Sectin 8. Expsure cntrls/persnal prtectin Sectin 9. Physical and chemical prperties Sectin 10. Stability and reactivity Sectin 11. Txiclgical infrmatin Sectin 12. Eclgical infrmatin Sectin 13. Dispsal cnsideratins Sectin 14. Transprt infrmatin Sectin 15. Regulatry infrmatin Sectin 16. Other infrmatin, including date f preparatin r last revisin Sectins may be included in the SDS, but are nt required by OSHA. OSHA anticipates that, in additin t safety and health benefits, the revised HCS will result in fur types f prductivity benefits: (1) fr chemical manufacturers, because they will need t prduce fewer SDSs in future years; (2) fr emplyers, in prviding training t new emplyees as required by the existing OSHA HCS thrugh the imprved cnsistency f the labels and SDSs. (3) fr firms engaging in, r cnsidering engaging in, internatinal trade. SUMMARY Basically, if yu have a current Hazard Cmmunicatin Prgram, including a written prgram, inventry cntrl and training, the majr changes that will affect mst cmpanies will be the Safety Data Sheet, Labels and Pictgrams. The changes frm MSDS t SDS will make it much easier t standardize the Safety Data Sheets as the required infrmatin will be in the same place n each SDS. Label changes are easy t d and almst every label vendr nw has these new labels available. Pictgrams will take just a while lnger t learn and implement, but this will simplify the infrmatin fr almst everyne using chemicals and hazardus materials. Training is always an imprtant part f any new prgram. Organizatins with a current HAZCOM prgram can make these adjustments quickly and include these new basics in training. Overall, GHS is nthing t fear, it s a simplified system and in the lng run, will result in greater efficiency, prductivity and f curse, great safety and health fr anyne wrking with chemicals and hazardus materials. 7

8 LEADER S GUIDE This Leader s Guide is prvided t assist in cnducting a successful presentatin. INTRODUCTION: A brief descriptin f the prgram. PROGRAM OUTLINE: Summarizes the prgram cntent. The prgram will be mre meaningful if the utline is discussed prir t the presentatin f the vide. PREPARING FOR AND CONDUCTING THE PRESENTATION: These sectins will help yu set up the training envirnment, help yu relate the prgram t site-specific incidents, and prvide prgram bjectives fr fcusing yur presentatin. REVIEW QUESTIONS AND ANSWERS: Questins may be cpied and given t participants t dcument hw well they understd the infrmatin that was presented. Answers t the review questins are prvided separately. ATTENDANCE RECORD: Dcument the date f yur presentatin, as well as identify the prgram participants. The attendance recrd may be cpied as needed. INTRODUCTION The Glbal Harmnized System (GHS) is an Internatinal apprach t hazard cmmunicatin. It is based n majr existing systems arund the wrld, including OSHA s Hazard Cmmunicatin Standard and the chemical classificatin and labeling systems f ther US agencies. This prgram explains hw t cmply withut changing the entire HAZCOM prgram. PROGRAM OUTLINE Intrductin The GHS is an Internatinal apprach t hazard cmmunicatin. GHS prvides agreed criteria fr classificatin f chemical hazards and standard apprach t label elements and safety data sheets. The result f the negtiatin prcess is the United Natins dcument Glbally Harmnized System f Classificatin and Labeling f Chemicals referred t as The Purple Bk. OSHA has mdified the Hazard Cmmunicatin (HCS) t adpt the GHS t imprve safety and health f wrkers with mre effective cmmunicatin. The GHS prvides a standard apprach fr determining what hazardus effects a chemical pses. This will enhance bth emplyer and wrker cmprehensin f the hazards which will ensure apprpriate handling and safe use f wrkplace chemicals. 8

9 The harmnized frmat f the safety data sheets will enable emplyers, wrkers, health prfessinals, and emergency respnders t access the infrmatin mre efficiently. Adptin f the GHS in the United States and arund the wrld will imprve infrmatin received frm ther cuntries. During the phase-in perid, emplyers wuld be required t be in cmpliance with either the existing HCS r the revised HCS r bth. OSHA recgnizes that hazard cmmunicatin prgrams will g thrugh a perid where labels and SDSs under bth standards will be present in the wrkplace. This is acceptable and emplyers are nt required t maintain tw sets f labels and SDSs fr cmpliance purpses. Changes t HAZCOM OSHA is requiring that emplyees be trained n the new label elements (pictgrams and signal wrds and the new SDS frmat by December The three majr areas f change are in hazard classificatin, labels, and safety data sheets: Hazard classificatin The hazard definitins have been changed t prvide specific criteria fr classificatin f health and physical hazards, as well as classificatin f mixtures. Labels Chemical manufacturers and imprters will be required t prvide a label that includes a harmnized signal wrd, pictgram, and hazard statement fr each hazard class and categry. Precautinary statements must als be prvided. Safety Data Sheets The sheets will have a specified 16-sectin frmat. The HCS is a mdificatin t the existing standard. Parts f the standard that did nt relate t GHS remained unchanged. Sme mdificatins t terminlgy in rder t align the revised HCS with language used in the GHS. hazard determinatin has been changed t hazard classificatin. Material Safety Data Sheets is changed t Safety Data Sheets. Hazard Classificatin The revised HCS has specific criteria fr each health and physical hazard and detailed instructins fr hazard evaluatin and determinatins as t whether mixtures r substances are cvered. Establishes bth hazard classes and hazard categries fr mst f the effects. The classes are divided int categries that reflect the relative severity f the effect. 9

10 The current HCS des nt include categries fr mst f the health hazards cvered. Labels Under the current HCS the label preparer must prvide the identity f the chemical and the apprpriate hazard warnings. Under the revised HCS, nce the hazard classificatin is cmpleted the standard specifies what infrmatin is t be prvided fr each hazard class and categry. Labels will require the fllwing elements: Pictgram a symbl plus ther graphic elements such as a brder, backgrund pattern, r clr that is intended t cnvey specific infrmatin abut the hazards f a chemical. Each pictgram cnsists f a different symbl n a white backgrund within a red square frame set n a pint. There are nine pictgrams under the HCS; nly eight pictgrams are required under HCS. The signal wrds used are "danger" and "warning." "Danger" is used fr the mre severe hazards, while "warning" is used fr less severe hazards. Hazard Statement: a statement assigned t a hazard class and categry that describes the nature f the hazard(s) f a chemical, including, where apprpriate, the degree f hazard. Precautinary Statement: a phrase that describes recmmended measures t be taken t minimize r prevent adverse effects resulting frm expsure t a hazardus chemical r imprper strage r handling f a hazardus chemical. Health Hazard (flame) Carcingen - Mutagenicity - Reprductive Txicity - Respiratry Sensitizer - Target Organ Txicity - Aspiratin Txicity - Flammables - Pyrphrics - Self-Heating - Emits Flammable Gas - Self-Reactives - Organic Perxides - Irritant (skin and eye) - Skin Sensitizer - Acute Txicity (harmful) - Narctic Effects - Respiratry Tract Irritant - Hazardus t Ozne Layer. Crrsin (Explding Bmb) Gases under Pressure - Skin Crrsin/burns - Eye Damage - Crrsive t Metals - Explsives Self-Reactives - Organic Perxides. 10

11 Envirnment (Flame ver Circle) Nn-mandatry. Skull and Crssbnes Oxidizers Aquatic Txicity Acute Txicity (fatal r txic) Mre n Pictgrams Under the revised HCS, pictgrams must have red brders. OSHA believes that the use f the red frame will increase recgnitin and cmprehensibility. The red frame is required regardless f whether the shipment is dmestic r internatinal. The revised (HCS) requires that all red brders printed n the label have a symbl printed inside it. Emplyers may chse t label wrkplace cntainers either with the same label that wuld be n shipped cntainers fr the chemical under the revised rule, r with label alternatives that meet the requirements fr the standard. Alternative labeling systems such as the Natinal Fire Prtectin Assciatin (NFPA) 704 Hazard Rating and the Hazardus Material Infrmatin System (HMIS) are permitted fr wrkplace cntainers. The infrmatin supplied n these labels must be cnsistent with the revised HCS, such as n cnflicting hazard warnings r pictgrams. New Safety Data Sheets (SDS) The infrmatin required n the SDS will remain essentially the same as that in the current standard. The current HCS indicates what infrmatin has t be included n an SDS but des nt specify a frmat fr presentatin r rder f infrmatin. The revised HCS requires that the infrmatin n the SDS is presented using cnsistent headings in a specified sequence. The SDS frmat is the same as the ANSI standard frmat which is widely used in the U.S. and is already familiar t many emplyees. 11

12 The frmat f the 16-sectin SDS shuld include the fllwing sectins: (1) Identificatin (2) Hazard(s) identificatin (3) cmpsitin/infrmatin n ingredients (4) first- aid measures (5) fire-fighting measures (6) accidental release measures (7) handling and strage (8) expsure cntrls/persnal prtectin (9) physical and chemical prperties (10) stability and reactivity (11) txiclgical infrmatin (12) eclgical infrmatin (13) dispsal cnsideratins (14) transprt infrmatin (15) regulatry infrmatin (16) ther infrmatin, including date f preparatin r last revisin (12-15) may be included in the SDS but nt an OSHA requirement. OSHA anticipates the revised HCS will result in fur types f prductivity benefits: (1) fr chemical manufacturers because they will need t prduce fewer SDSs in future years (2) fr emplyers in prviding training t new emplyees as required by the existing OSHA HCS thrugh the imprved cnsistency f labels and SDSs (3) fr firms engaging in, r cnsidering engaging in Internatinal trade. The three benefits listed abve are in additin t the benefit f imprved safety and health. Summary The majr changes frm MSDS t SDS will make it much easier t standardize Safety Data Sheets as the required infrmatin will be in the same place n each SDS. Label changes are easy t d and every label vendr nw has these new labels available. Pictgrams will take just a while lnger t learn and implement. Training is always an imprtant part f any new prgram. Overall, GHS is nthing t fear; it s a simplified system and in the lng run, will result in greater efficiency, prductivity and f curse, great safety and health fr anyne wrking with chemicals and hazardus materials. 12

13 Hazard Cmmunicatins Hw T Cmply With GHS TRUE/FALSE QUIZ 1. The Glbal Harmnized System (GHS) is an Internatinal apprach t hazard cmmunicatin, prviding agreed criteria fr classificatin f chemical hazards and a standardized apprach t label elements and safety data sheets. 2. The mdificatins t terminlgy in rder t align the revised Hazard Cmmunicatin Standard (HCS) with language used in the GHS. Hazard determinatin has been changed t Hazard warnings. 3. There are nine pictgrams under the GHS t cnvey the health, physical and envirnmental hazards. 4. The Safety Data Sheets (SDS) frmat is the same as the ANSI standard frmat which is widely used in United States and is already familiar t many emplyees. 5. Under the current HCS the label preparer must prvide the identity f the chemical and the apprpriate hazard warnings. MULTIPLE CHOICE 6. The areas f majr HAZCOM changes are in. a. hazard classificatin b. labels c. safety data sheets d. all f the abve 13

14 7. OSHA is requiring that emplyees are trained in the new label elements such as pictgrams and signal wrds and the new SDS frmat by. a. December 2012 b. December 2013 c. December 2014 d. nne f the abve 8. Wrds used t indicate the relative level f severity f hazard and alert the reader t a ptential hazard n the label is/are. a. danger & warning b. alert c. cautin d. all f the abve 9. Under the revised HCS, pictgrams must have brders. a. red b. black c. blue d. green 10. OSHA anticipates that, in additin t safety and health benefits, the revised HCS will result in prductivity benefits such as. a. prduce fewer SDSs b. emplyers prvide training c. firms cnsidering engaging in Internatinal trade d. all f the abve 14

15 Hazard Cmmunicatins Hw T Cmply With GHS TRUE/FALSE QUIZ ANSWERS 1. The Glbal Harmnized System (GHS) is an Internatinal apprach t hazard cmmunicatin, prviding agreed criteria fr classificatin f chemical hazards and a standardized apprach t label elements and safety data sheets. 2. The mdificatins t terminlgy in rder t align the revised Hazard Cmmunicatin Standard (HCS) with language used in the GHS. Hazard determinatin has been changed t Hazard warnings. 3. There are nine pictgrams under the GHS t cnvey the health, physical and envirnmental hazards. 4. The Safety Data Sheets (SDS) frmat is the same as the ANSI standard frmat which is widely used in United States and is already familiar t many emplyees. 5. Under the current HCS the label preparer must prvide the identity f the chemical and the apprpriate hazard warnings. MULTIPLE CHOICE 6. The areas f majr HAZCOM changes are in. a. hazard classificatin b. labels c. safety data sheets d. all f the abve 15

16 7. OSHA is requiring that emplyees are trained in the new label elements such as pictgrams and signal wrds and the new SDS frmat by. a. December 2012 b. December 2013 c. December 2014 d. nne f the abve 8. Wrds used t indicate the relative level f severity f hazard and alert the reader t a ptential hazard n the label is/are. a. danger & warning b. alert c. cautin d. all f the abve 9. Under the revised HCS, pictgrams must have brders. a. red b. black c. blue d. green 10. OSHA anticipates that, in additin t safety and health benefits, the revised HCS will result in prductivity benefits such as. a. prduce fewer SDSs b. emplyers prvide training c. firms cnsidering engaging in Internatinal trade d. all f the abve 16