The New Hazard Communication GHS Container Labels

Transcription

1 HAZMAT ROB S BLOG The New Hazard Communication GHS Container Labels For about 30 years, manufacturers, distributors and importers have, voluntarily or mandatorily, provided Material Safety Data Sheets (MSDS) or Safety Data Sheets (SDS) and information on containers to convey the physical and health hazards of their hazardous chemicals to protect any downstream workers that may be exposed in the workplace. There have been countless systems developed and used over the years for this hazard communication. In the U.S. it is codified under 29 CFR Hazard Communication. On March 26, 2012, OSHA modified to align with the United Nations Global Harmonization System of Classification and Labeling of Chemicals to reduce the burden on companies and increase the quality and consistency of information regarding chemical hazards and their associated protective measures in the workplace and transportation. There are three Information Communication Components under the new Regulations based on the UN s GHS: Labels, Written Safety Data Sheets or SDS, and Training. LABELS 1) Labels on the containers with 6 components on each label under (f). Each container label must have: Product Identifier (name or number); Signal word(s) (i.e., DANGER or WARNING); Hazard Statement(s) (i.e. Highly Flammable Liquid & Vapor) Red bordered diamond shaped pictogram(s) (i.e., skull & crossbones or flame); Precautionary Statement(s), (including specific prevention, response, storage and disposal statements); and Name, address, telephone number of the distributor, manufacturer, importer, or other responsible party. SAFETY DATA SHEETS (SDS) 2) A written 16 Section (12 of them mandatory) Safety Data Sheet or SDS with the following sections; 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 Toxicology information Section 12 Ecological information (non-mandatory) Section 13 considerations (non-mandatory) Section 14 Transport information (non-mandatory) Section 15 Regulatory information (non-mandatory) Section 16 Other information including date of preparation of last revision.

2 TRAINING 3) Training on the Hazard Communication Information, the new Hazard Communication Labeling Information and the Safety Data Sheets (SDS) new mandatory format. The biggest change under the GHS-aligned regulations would have to be the new container information or the Hazard Communication Labels. The label information contains standardized information so no matter who provides the information, the chemicals would have the same exact information.

3 The Harmonization component of the new regulations is not only to harmonize the worker protection regulations around the world but to harmonize the hazard classes under the OSHA Worker Protection Regulations with the DOT/International Transportation Requirements. For example, take a pure chemical like under both DOT and OSHA. Acetone is classified as a Hazard Class 3 or Flammable Liquid under the DOT Transportation Regulations in the 49 CFR Hazardous Materials Table. Using 29 CFR Appendix B.6, the DOT Flammable Liquid is also classified as a Flammable Liquid under OSHA because flashes below 200 degrees. Then under OSHA, the Flammable Liquid Hazard Class is further broken down into 4 Hazard Categories - Category 1, Category 2, Category 3, and Category 4. The DOT Hazardous Materials Regulations have a similar system of 3 Hazard Categories for their hazard classes, called Packing Groups: PG I, PG II or PG III, further denoting the severity of the hazard. The DOT regulations in (a) state that if a material has a flash point of 140 degrees or less, it would be shipped as a Class 3 Flammable Liquid, and under (b), a material with a flash point above 140 degrees up to 200 degrees would be classed as a Combustible Liquid. If you compare that to Appendix B.6, a hazardous chemical that flashes at 200 degrees or less is a Flammable Liquid under OSHA. Under , OSHA also requires the Signal Words Combustible Liquid on the Hazard Chemical Labels for flammable liquids that flash above 140 degrees up to 200 degrees. They both seem to have the same definition for the Flammable Liquid Hazard Class of not more than 140 degrees and Combustible Liquid of above 140 up to 200 degrees. But that is not where the similarities end. Under both DOT and OSHA, the Packing Groups and Hazard Categories are in most cases similar if not identical. In DOT s Assignment of Packing Groups for Class 3 Flammable Liquids and OSHA s Appendix B.6, you will see that PG I and Hazard Category 1 have the same criteria. DOT and OSHA both state that if a material has a boiling point of less than 95 degrees (the chemical would have to boil out of the container at temperatures below 95 degrees), it is a PG I and Hazard Category 1. Water boils at 212 degrees, but water only gives off steam, not flammable vapors. PG I and Category 1 are considered to be the most dangerous. PG II under DOT and Hazard Category 2 under OSHA carry a flash point of not more than 73 degrees. Then for PG III under DOT and Category 3 under OSHA they both use the flash point above 73 degrees but less than 140 degrees. Then finally, above 140 degrees up to 200 degrees, would be Combustible Liquid under DOT in bulk containers and in Appendix C.4.19, the Hazard Statement on the Container Labels would also be Combustible Liquid for Hazard Category 4 under OSHA. DOT PG I and OSHA Category 1 have boiling points below 95 degrees DOT PG II and OSHA Category 2 are for Flammable Liquids that have flash points at 73 degrees or less DOT PG III and OSHA Category 3 flash from 73 degrees up to 140 degrees and DOT (no PG IV) and OSHA Category 4 state that above 140 degrees up to 200 degrees would be a Combustible Liquid. Acetone does not boil below 95 degrees but does have a flash point below 73 degrees; therefore, it would be classified as a Flammable Liquid under DOT and OSHA. Then, when we break Acetone

4 down into the Packing Group under DOT and the Hazard Category under OSHA, Acetone would be a PG II in the truck and also a Hazard Category 2 in the plant when protecting workers. Using (f), Appendices C.4.5, C.4.11, and C.4.19; the Health Hazard Classifications in Appendix A; and the Physical Hazard Classifications in Appendix B, the containers of Acetone meet the health hazard classifications for Eye Damage/Irritation Category 2A and Specific Target Organ Toxicity (Single Exposure) Category 3, and the physical hazard classification for Flammable Liquid Category 2.

5 Then as specified in Appendix C the container label would have to include the Identifier, Signal Word DANGER, and the Hazard Statements HIGHLY FLAMMABLE LIQUID AND VAPOR, CAUSES SERIOUS EYE IRRITATION, AND MAY CAUSE DROWSINESS OR DIZZINESS. The fourth component of the Hazard Container Labels under the GHS-based regulations would be the diamond shaped pictogram, which in Appendix C.4.19 Category 2 for Flammable Liquids (Acetone), is the FLAME Pictogram and in Appendices C.4.5 Category 2A and C.4.11 Category 3 is the EXCLAMATION POINT., DANGER, HIGHLY FLAMMABLE LIQUID AND VAPOR, CAUSES SERIOUS EYE IRRITA- TION, MAY CAUSE DROWSINESS OR DIZZINESS.

6 After the Product Identifier, Signal Word, Hazard Statement and the Pictogram comes the fifth component of the new GHS label, the Precautionary Statements. There are four Precautionary Statement areas indicated for each classification in Appendix C,, and. Finally, the Name, Address, Phone Number of a responsible party would be required on the OSHA Hazard Communication Labels. So, the containers of Acetone would display the following information: DANGER HIGHLY FLAMMABLE LIQUID AND VAPOR, CAUSES SEVERE EYE IRRITATION, MAY CAUSE DROWSINESS OR DIZZINESS. PREVENTION KEEP AWAY FROM HEAT, SPARKS, OPEN FLAMES, HOT SURFACES, NO SMOKING KEEP CONTAINERS TIGHTLY CLOSED USE EXPLOSION-PROOF ELECTRICAL, VENTILATING, LIGHTING EQUIPMENT USE NON-SPARKING TOOLS TAKE PRECAUTIONARY MEASURES AGAINST STATIC DISCHARGE WEAR PROTECTIVE GLOVES/EYE PROTECTION/FACE PROTECTION WASH HANDS THOROUGHLY AFTER HANDLING AVOID BREATHING FUMES USE ONLY OUTDOORS OR IN A WELL-VENTILATED AREA RESPONSE IF ON SKIN OR HAIR TAKE OFF IMMEDIATELY ALL CONTAMINATED CLOTHING. RINSE SKIN WITH WATER AND/OR SHOWER IN CASE OF FIRE USE CARBON DIOXIDE, DRY CHEMICAL POWDER OR FOAM TO EXTINGUISH 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 IF INHALED: REMOVE PERSON TO FRESH AIR AND KEEP COMFORTABLE FOR BREATHING CALL MEDICAL PERSONNEL IF YOU FEEL UNWELL STORAGE STORE IN A WELL VENTILATED PLACE, KEEP COOL KEEP CONTAINER TIGHTLY CLOSED STORE LOCKED UP DISPOSAL DISPOSE OF CONTENTS AND CONTAINERS ACCORDING TO EPA CFR PART 260 THE HAZARDOUS WASTE MANAGEMENT SYSTEM, PART 261 IDENTIFICATION OF HAZARDOUS WASTES, PART 262 STANDARDS APPLICABLE TO GENERATORS OF HAZARDOUS WASTES OR IN ACCORDANCE WITH LOCAL, REGIONAL, NATIONAL AND INTERNATIONAL REGULATIONS. ABC Corp., 555 Main St., Anytown, PA 19530, (555) The Hazard Communication Label Information will be required for responsible parties on containers before June 1, 2015.

7 Combination packaging for a Category 2 (PG II) flammable liquid (Class 3) (App. A, B) Outer Packaging: Box with UN# Shipping Name, a DOT 4 x 4 transport label* Inner Packaging: Plastic bottle with GHS hazard communication warning label** UN1090 UN1090 May cause drowsiness or dizziness * Only the DOT transport markings and labels are required for outer packages. ** Where a pictogram required by DOT appears on a shipped container, the pictogram specified in Appendix C.4 for the same hazard shall not appear.

8 I am really looking forward to explaining these new and important regulations. Be aware that the March 26 Federal Register mandated other changes under OSHA in addition to so be sure to check the final rule on our website yourself, as I can not cover all the changes in my blog. All the changes are included in the new Compliance Guide as well. If you have any input on the New GHS Hazard Communication Rule, call, or drop us a line and we would be thrilled to help you meet these new regulations as they come into effect over the next few years. Finally, please note that DOT has just issued a new International Harmonization Final Rule under HM- 215L, which is available on our website. Thank you! Robert J. Keegan Publisher Hazardous Materials Publishing Company