GHS & Your Hazard Communication Program

Transcription

1 GHS & Your Hazard Communication Program Kay Rowntree, CIH Industrial Hygiene Sciences, LLC

2 Objectives Learn what GHS is about Outline the changes made to OSHA s Hazard Communication Standard to align it with GHS Describe the impacts these changes will have on your company s Hazard Communication Program

3 What is GHS? The Globally Harmonized System of Classification & Labeling of Chemicals A system for standardizing and harmonizing the classification and labeling of chemicals Not a regulation, not a treaty obligationroots are in a 1992 UN mandate Builds on the best of existing regulations in the US, EU, Canada and the UN Transport Regulations

4 Goals of GHS Will not reduce current employee protection Establishes agreed upon hazard classification & communication provisions and provides an explanatory system for applying them Allow countries to use the criteria and implement them into their own regulatory structure

5 GHS Creates a Common Basis Defining the health, physical and environmental hazards of chemicals; Classifying those hazards Communicating hazard information and protective measures on labels and Safety Data Sheets (SDS)

6 Why GHS? Different hazard definitions leads to classifying something as hazardous in one country but not in another Differences in required information makes it more difficult to prepare labels and safety data sheets Reduces the need for testing & evaluation against multiple classification systems

7 Example of Variations in Criteria From: AFS 24 th Environmental, Health & Safety Conference

8 GHS Criteria From:

9 Benefits of GHS Safer work environment Consistent, simplified information on hazards & safety procedures or practices Better information on potential severity of hazards Easier to train employees Easier for employees to recognize hazards and take appropriate actions Reduced regulatory costs (maybe)

10 What Impact Does GHS Have on OSHA s Hazard Communication Standard (HCS)? Changes terminology hazard definitions labeling requirements MSDSs (SDSs) format What has not changed the basic nuts and bolts of HCS Provision of SDSs and labels chemical users have to get SDSs employees must be educated AFS 24 th Environmental, Health & Safety Conference

11 GHS Terminology SDS (formerly called MSDS) Safety Data Sheet Product Identifier (formerly called Product Name) Hazard group Health Physical Environmental

12 GHS Terminology Class Describes the intrinsic hazard(s) of a substance Within each classes there are rules or criteria for classification Each hazard group has its own list of classes. Category Describes in more detail the nature of the hazard(s) within a class Each category has rules or criteria for classification

13 Hazard Statements GHS Terminology Short statements about the hazard(s) Standardized language Based on the classification Must appear on the label and on the SDS Numerical codes describe hazards Precautionary Statements Phrases and/or pictograms that describe what measures should be taken to prevent adverse effects Covers personnel, storage or handling related protection Based on the classification Numerical codes describe precautions

14 GHS Terminology Signal word Communicates the level of hazard Only 2 signal words- Danger and Warning Choice is based on the classification Must be on the label and SDS There are classifications in which no signal word is required Pictogram A standardized visual symbol that conveys the potential hazard(s) Must be on the label and SDS Choice(s) are based on the classification There are classifications for which no pictogram is required

15 GHS Summary For each class and category of hazard there are a harmonized Signal Word Pictogram(s) Hazard Statement(s) Precautionary Statement(s) Once a chemical is classified, the GHS provides the specific core information that must be conveyed to users. This information generally reflects the degree of severity of the hazard. AFS 24 th Environmental, Health & Safety Conference

16 What Does GHS Mean to You? You will have to learn a new hazard communication language and use it when you train employees and prepare MSDSs and labels

17 Hazard Classification The heart of the program The definitions of hazards in GHS are more specific and detailed than those in the old HCS Classification requires identification of hazards review of existing scientific data Covers Physical hazards Health hazards Environmental hazards

18 Physical Hazard Classes Explosives Flammable Gases Flammable Aerosols Oxidizing Gases Gases Under Pressure Flammable Liquids Flammable Solids Self-Reactive Substances Pyrophoric Liquids Pyrophoric Solids Self-Heating Substances Substances which in contact with water emit flammable gases Oxidizing Liquids Oxidizing Solids Organic Peroxides Corrosive to Metals

19 Example of A Physical Hazard Category & Its Criteria Category Criteria 1 Flash point < 23 C (73.4 F) & initial boiling point 35 C (95 F) 2 Flash point < 23 C (73.4 F) & initial boiling point > 35 C (95 F) 3 Flash point 23 C (73.4 F) and 60 C (140 F) 4 Flash point > 60 C (140 F) and 93 C (199.4 F)

20 Health Hazard Classes Acute toxicity Skin corrosion/irritation Serious eye damage/eye irritation Respiratory or skin sensitization Germ cell mutagenicity Carcinogenicity Reproductive toxicity Specific target organ toxicity- single exposure Specific target organ toxicity - repeated exposure Aspiration hazard (not covered under GHS but OSHA added it) Simple asphyxiants (not covered under GHS but OSHA added it)

21 Example of A Health Hazard Category & Its Criteria Hazard Category & Sub-Categories for Respiratory Sensitizers Category Definition 1A 1B Criteria A substance is classified as a respiratory sensitizer: (a) if there is evidence in humans that the substance can lead to specific respiratory hypersensitivity and/or (b) if there are positive results from an appropriate animal test. Substances showing a high frequency of occurrence in humans; or a probability of occurrence of a high sensitization rate in humans based on animal or other tests. Severity of reaction may also be considered. Substances showing a low to moderate frequency of occurrence in humans; or a probability of occurrence of a low to moderate sensitization rate in humans based on animal or other tests. Severity of reaction may also be considered Effects seen in either humans or animals will normally justify classification in a weight of evidence approach for respiratory sensitizers. Substances may be allocated to one of the two sub-categories 1A or 1B using a weight of evidence approach in accordance with the criteria given in Table A.4.1 and on the basis of reliable and good quality evidence from human cases or epidemiological studies and/or observations from appropriate studies in experimental animals. AFS 24 th Environmental, Health & Safety Conference

22 Environmental Hazard Classes Hazards to the aquatic environment (acute and chronic) Hazards to the ozone layer OSHA has no jurisdiction over these so they cannot require them under HCS

23 OSHA Specifics Retained the requirements to include NTP and IARC for carcinogenicity assessments Addressed hazards not otherwise classified (called unclassified hazards in the proposal) Simple asphyxiants Must be addressed on SDSs and labels (Signal word=warning) Hazard Statement: May displace oxygen and cause rapid suffocation Pyrophoric gases Combustible dusts Must be addressed on SDSs and labels (Signal word=warning) Hazard Statement: May form combustible dust concentrations in the air

24 Hazard Statements A statement assigned to a hazard class and category Describes the nature of the hazards of a chemical, including, where appropriate, the degree of hazard. 72 individual and 17 combined Will replace EU R phrases seen on European SDSs

25 Examples of Hazard Statements Causes eye irritation Causes mid skin irritation Causes serious eye damage Causes serious eye irritation Causes severe skin burns and eye damage Causes skin irritation Combustible liquid Contains gas under pressure; may explode if heated Contains refrigerated gas; may cause cryogenic burns or injury Explosion; fire, blast or projection hazard Explosion; mass explosion hazard Explosion; severe projection hazard Extremely flammable aerosol Extremely flammable gas Extremely flammable liquid and vapour Fatal if inhaled Fatal if swallowed Fatal in contact with skin Fire or projection hazard Flammable aerosol Flammable gas Flammable liquid and vapour Flammable solid Harmful if inhaled Harmful if swallowed

26 Precautionary Statements A statement assigned to a hazard class & category 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. Types of Precautionary Statements General Prevention Response in case of spill or exposure Storage Disposal 116 individual & 33 combined

27 Examples of Precautionary Statements Obtain special instructions before use Do not handle until all safety precautions have been read and understood Keep away from heat/sparks/open flames/hot surfaces No smoking Do not spray on an open flame or other ignition source Do not allow contact with air Keep away from any possible contact with water, because of violent reaction and possible flash fire Protect from moisture Keep container tightly closed Ground/bond container and receiving equipment Use only non-sparking tools Take precautionary measures against static discharge Do not breathe dust/fume/gas mist/vapours/spray Use only outdoors or in a well-ventilated area

28 Signal Words A word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label Choice is driven by the hazard classification and category 'Danger' is used for more severe hazard(s) Warning' is used for less severe hazard(s)

29 Required elements for shipped containers Product identifier (must match the SDS) Supplier information Pictograms Signal Words Hazard statements Labels Precautionary statements Supplemental info will be allowed but can t contradict GHS

30 More About Labels Pictograms must follow GHS requirements and have a red border OSHA cannot require the pictogram for environmental hazards but you will still see it on labels The precedence of the Signal Words, Pictogram is defined Appendix C describes label requirements AFS 24 th Environmental, Health & Safety Conference

31 Example of GHS Label Elements by Classification From:

32 More on Labels OSHA still will require that labels be in English legible prominently displayed Labels must be updated within 6 months after a manufacturer, distributor or importer receives information that the classification has changed; any chemicals shipped after that time must have the new labels

33 What About Casting Labels? For solid metal, wood or plastic items that are not excluded as an article (f)(4)(i) the required label can be transmitted at time of the initial shipment Doesn't need to be included in subsequent shipment unless info on the label changes only applies to the solid material itself not to anything used in conjunction or present with the item to which downstream users may be exposed Is your casting in the final form? Will your customer use processes on your casting that could generate dust or fumes?

34 In-Plant Container Labels Same label that would be on shipped container for the chemical OR Product identifier and words, pictures, symbols, or 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. Do HMIS and NFPA labels qualify?

35 More on In-Plant Labeling Alternative systems can t have pictograms or signal words that conflict with GHS Can use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process container but still must meet criteria on previous slide info must be readily accessible in work area Portable container exemption still in

36 Pictograms What is It? Pictogram Hazard Class/Category Exploding Bomb Unstable explosives Explosives of Divisions 1.1, 1.2, 1.3, 1.4 Self reactive substances and mixtures, Types A,B Organic peroxides, Types A,B Flame Flammable gases, category 1 Flammable aerosols, categories 1,2 Flammable liquids, categories 1,2,3 Flammable solids, categories 1,2 Self-reactive substances and mixtures, Types B,C,D,E,F Pyrophoric liquids, category 1 Pyrophoric solids, category 1 Self-heating substances and mixtures, categories 1,2 Substances and mixtures, which in contact with water, emit flammable gases, categories 1,2,3 Organic peroxides, Types B,C,D,E,F

37 More Pictograms What is It? Pictogram Hazard Class/Category Flame over a Circle Oxidizing gases, category 1 Oxidizing liquids, categories 1,2,3 Cylinder Gases under pressure: - Compressed gases - Liquefied gases - Refrigerated liquefied gases - Dissolved gases Corrosion Corrosive to metals, category 1 Skin corrosion, categories 1A,1B,1C Serious eye damage, category 1 Skull & Crossbones Acute toxicity (oral, dermal, inhalation), categories 1,2,3

38 More Pictograms What is It? Pictogram Hazard Class/Category Exclamation Point Health Hazard Dead fish and tree Acute toxicity (oral, dermal, inhalation), category 4 Skin irritation, category 2 Eye irritation, category 2 Skin sensitisation, category 1 Specific Target Organ Toxicity Single exposure, category 3 Respiratory sensitization, category 1 Germ cell mutagenicity, categories 1A,1B,2 Carcinogenicity, categories 1A,1B,2 Reproductive toxicity, categories 1A,1B,2 Specific Target Organ Toxicity Single exposure, categories 1,2 Specific Target Organ Toxicity Repeated exposure, categories 1,2 Aspiration Hazard, category 1 Hazardous to the aquatic environment - Acute hazard, category1 - Chronic hazard, categories 1,2 AFS 24 th Environmental, Health & Safety Conference

39 Sample GHS Label AFS 24 th Environmental, Health & Safety Conference

40 Safety Data Sheets (SDSs) Requirements spelled out in Appendix D 16 part format essentially same as ANSI Sections must be in the order listed in the following slides Several sections will not be made mandatory by OSHA (Sections 12-15) Must be in English If no relevant info is found for any Physical Hazard subheading, then it must be marked as No Applicable Information found Employers still have to obtain SDS and make them accessible (no barriers) to employees during each shift

41 SDS Sections1-4 Section 1: Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use. Section 2: Hazard(s) identification includes all hazards regarding the chemical; required label elements. Section 3: Composition/information on ingredients includes information on chemical ingredients; trade secret claims. Section 4: First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.

42 SDS Sections 5-7 Section 5: Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire. Section 6: Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup. Section 7: Handling and storage lists precautions for safe handling and storage, including incompatibilities.

43 SDS Sections 8-10 Section 8: Exposure controls/personal protection lists OSHA's Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE). Section 9: Physical and chemical properties lists the chemical's characteristics. Section 10: Stability and reactivity lists chemical stability and possibility of hazardous reactions.

44 SDS Sections Section 11: Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity. Section 12: Ecological information* Section 13: Disposal considerations* Section 14: Transport information* Section 15: Regulatory information* Section 16: Other information, includes the date of preparation or last revision. * Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15

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46 Training Nuts and bolts are the same Training can cover categories of hazards or specific chemicals Have to include training on hazards not otherwise classified as well as health and physical hazards Training has to cover new labels & SDSs

47 Modifications to Other OSHA Standards Flammable & Combustible Liquids ( & ), Dipping & Coating ( ) conform categories, terminology, flashpoints (FP) and boiling points to GHS Update acceptable means of determining flash points Welding, Cutting & Brazing ( ) Process Safety Management of Highly Hazardous Chemicals ( ) HAZWOPER ( ) Occupational Exposure to Hazardous Chemicals in Laboratories ( ) Substance specific standards (asbestos, cadmium, lead, formaldehyde etc.)- sections on labeling, signs & references to MSDSs changed to align with GHS AFS 24 th Environmental, Health & Safety Conference

48 Important Deadlines December 1, 2013-employers must train or re-train employees regarding new label elements and SDS format June 1, all labels and SDSs must be updated by chemical manufacturers/distributors or importers Distributors have an additional 6 months to distribute containers with manufacturers labels to accommodate containers received close to the compliance date June 1, employers have to update their Haz Com program and signs

49 What Does GHS Mean to You? You will be seeing new SDSs & labels You will need to replace your old MSDSs with new SDSs You will need to ensure that labels meet GHS requirements You will need to train your employees to read the new SDSs and labels You will have to produce a GHS compliant SDS for your castings if not shipped in final form

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51 For additional information, please contact: Kay Rowntree, CIH Industrial Hygiene Sciences, LLC 602 Fox Knoll Drive Waterford, WI