OSHA GHS What s needed to be compliant? Webinar Details

Transcription

1 OSHA GHS What s needed to be compliant? November 13, 2013 Sponsored by: Hosts Webinar Details Cheryl Skjolaas UWEX Madison/Extension Center for Agricultural Safety and Health Mark Hagedorn UWEX Eau Claire County Agricultural Agent and Dairy Team Co- Leader Audio - Please mute your phone Discussion Tools Questions 1

2 Bios & Contacts Mary Bauer Eau Claire Area OSHA Office Compliance Assistance Specialist (CAS) 1310 West Clairemont Ave Eau Claire, WI Compliance Officer for 20 Years CAS for 8 Years All in Eau Claire Area Office CIH: Certified Industrial Hygienist CSP: Certified Safety Professional Webinar Objectives Explaining GHS What is not changing What is changing Safety Data Sheets Labeling Suggestions for compliance 2

3 1983 Hazard Communication Standard Every employee has a Right to Know about chemicals and hazardous substances Chemical Manufacturers Responsibility for: Evaluating chemicals produced or imported Labeling and safety data sheets 3

4 Why Align HCS with GHS? GOAL: A common, coherent approach to classifying and communicating chemical hazards Harmonized definition of hazards Specific labeling criteria Standardized format for safety data sheets (SDS) GHS Benefits Improve quality and information and consistency of information Reduce confusion/increase comprehension of hazards Improve downstream risk management Facilitate training Address literacy levels a diverse workforce Facilitation of international chemical trade 4

5 Hazard Communication Standard (HazCom) Created to protect workers: provide information about chemical hazards and hazardous substances how to protect against those hazards What makes a chemical hazardous? Health hazards Physical hazards 5

6 Health Hazards Is it a: Carcinogen Corrosive Highly Toxic Irritant Sensitizer Toxic Target Organ Effects? Health Hazards Cause acute health problems -corrosives that can burn eyes or skin Cause chronic health problems - toxic chemicals that can cause long-term illnesses, such as cancer 6

7 Physical Hazards Flammable/Combustible Compressed Gas Explosive Organic Peroxide Oxidizer Pyrophoric Unstable Water Reactive What Hasn t Changed Chemical manufacturers and importers are required to: Obtain or develop a MSDS for each hazardous chemical produced or imported 7

8 What Hasn t Changed Distributors and suppliers: Ensuring that customers are provided a copy of MSDSs or SDSs. What Hasn t Changed Employers are required to: Develop a written program describing how the standard elements are implemented Maintain a list of all hazardous chemicals Obtain and make MSDS s or SDSs available to employees 8

9 What Hasn t Changed Employers are required to: Provide employees with HazCom training How to recognize, understand and use labels and MSDS s (SDS) Using safe procedures when working with hazardous substances Address non-routine tasks What Hasn t Changed Employees are required to: Read labels and MSDS s (SDS) Follow label and MSDS (SDS) instructions and warnings Know about chemicals they will use BEFORE attempting to use them 9

10 What Changed? Updates to HazCom became final on May 26, 2012 HazCom 2012 The majority of the changes involved adopting the Globally Harmonized Standard for Classification of Chemicals or GHS Most significant changes related to data sheets and labeling HazCom 2012 Safety Data Sheet or SDS will replace or update Material Safety Data Sheet (MSDS) 10

11 Safety Data Sheet Under HazCom 2012, SDS have been expanded from 9 to 16 sections Manufacturers must now follow a specific order or format Consistency Safety Data Sheet Sections will not be mandatory by OSHA - address information outside OSHA s jurisdiction Appendix D titled Safety Data Sheets has been added to the standard and details what is to be included in each section 11

12 Safety Data Sheet Format 1. Identification of the substance or mixture and of the supplier 2. Hazard identification 3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling and storage 8. Exposure controls/personal protection 9. Physical and chemical properties 10. Stability and reactivity 11. Toxicological information 12. Ecological information (non-mandatory) 13. Disposal considerations (non-mandatory) 14. Transport information (non-mandatory) 15. Regulatory information (non-mandatory) 16. Other information, including date of preparation or last revision Foot Baths Effectiveness: Multi-Purpose Health Hazards Pre-mixed Powder form Cost Effective Formaldehyde on List of Human Carcinogens 12

13 Sample SDS Sheet Sample SDS Sheet 13

14 Labeling Under HazCom 2012, labels are required to include: Product identifier (name) Name, address and telephone number of the chemical manufacturer, importer or other responsible party. Signal word Hazard statements Precautionary statements and. Pictograms Labeling Example 14

15 Pictograms Section 3 Hazard Identification Hazard Description Toxic Highly flammable Risk and Safety phrases R codes S codes 15

16 Risk Hazards Sample Risk Phrases Risk Phrase Flammable Highly flammable Extremely flammable Very toxic in contact with skin Very toxic if swallowed Risk Category Category 3 Category 2 Category 1 Category 2 Category 2 16

17 Combined Risk Phrases Very toxic by inhalation and in contact with skin Very toxic by inhalation and if swallowed Very toxic by inhalation, in contact with skin and if swallowed Very toxic in contact with skin and if swallowed 17

18 (j) Effective Dates Effective Completion Date December 1, 2013 Requirement's) Train employees on the new label elements and safety data sheet (SDS) format. Who Employers June 1, 2015* December 1, 2015 Compliance with all modified provisions of this final rule, except: The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label Chemical manufacturers, importers, distributors and employers June 1, 2016 Transition Period to the effective completion dates noted above Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. May comply with either 29 CFR (the final standard), or the current standard, or both Employers Chemical manufacturers, importers, distributors, and employers Your HazCom 2012 Program Between now and June 1, 2016 do the following: Conduct a thorough review of hazardous chemicals and substances used or stored at your facility Develop a list as it is required 18

19 Your HazCom 2012 Program On list have separate columns for MSDS and SDS Go through entire list and contact the manufacturer by phone or website to obtain a SDS If the SDS, is available get it! If not, at least have the MSDS Place a check in the SDS column as SDS forms are obtained Your HazCom 2012 Program Every 3 to 6 months go back to your list and attempt to obtain more SDS s until you get them all. Phase-in process - you will not be successful obtaining SDS s right away 19

20 Your HazCom 2012 Program Update labeling in written program Labels for portable containers in the workplace must have either: The same information as the manufacturer label with the exception of the manufacturer s address or Product identifier and words, pictures, symbols or combination which provide employees with specific information regarding the health and physical hazards of the chemical Tracking of Chemical Inventory Non-Mandatory/Optional Chemical Name MSDS Yes or No SDS Yes or No SDS Requested? Need by 6/1/2016 Label GHS Compliant? 20

21 NFPA and HMIS Labeling Systems These 2 labeling systems have been acceptable to OSHA for labeling portable containers for years NFPA and HMIS Labeling Systems Problem: Very general hazard information about the chemical Result: NFPA and HMIS labeling systems will no longer comply with HazCom 2012 labeling requirements 21

22 NFPA Diamond 4= Deadly Hazard 3= Severe Hazard 2= Moderate Hazard 1= Slight Hazard 0= No Hazard Other Warning Systems vs GHS NFPA uses 0-4 scales with 4 being most hazardous HMIS uses 0-4 scales with 4 being most hazardous GHS uses 1-4 scales with 1 being the most hazardous 22

23 Health Hazards Classifications Hazard Class Hazard Category Acute Toxicity Skin Corrosion/Irritation 1A 1B 1C 2 Serious Eye Damage/ Eye Irritation 1 2A 2B Respiratory or Skin Sensitization 1 Germ Cell Mutagenicity 1A 1B 2 Carcinogenicity 1A 1B 2 Reproductive Toxicity 1A 1B 2 Lactation STOT Specific Target Organ Toxicity - Single Exposure STOT Repeated Exposure 1 2 Aspiration 1 Simple Asphyxiants Single Category Hazard Class Physical Hazards Hazard Category Explosives Unstable Div 1.1 Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6 Explosives Flammable Gases 1 2 Flammable Aerosols 1 2 Oxidizing Gases 1 Gases under Pressure 1 Compressed Gases Liquefied Gases Refrigerated Liquefied Gases Dissolved Gases Flammable Liquids Self-Reactive Chemicals Type A Type B Type C Type D Type E Type F Type G Pyrophoric Liquids 1 Pyrophoric Solid 1 Pyrophoric Gases Single category Self-heating Chemicals 1 2 Chemicals, which in contact with water, emit flammable gases Oxidizing Liquids Oxidizing Solids Organic Peroxides Type A Type B Type C Type D Type E Type F Type G Corrosive to Metals 1 Combustible Dusts Single Category 23

24 Hazard category FLAMMABLE LIQUIDS (Classified in Accordance with Appendix B.6) Signal word Hazard statement 1 Danger Extremely flammable liquid and vapor 2 Danger Highly flammable liquid and vapor 3 Warning Flammable liquid and vapor Pictogram Flame Hazard category Signal word Hazard statement 4 Warning Combustible liquid Pictogram No Pictogram Your HazCom 2012 Program - Labeling Between now and June 2016 you need to.. Continue using the NFPA or HMIS labels compliant with current standard Look into HazCom 2012 compliant labeling systems for workplace containers and incorporate into your written program 24

25 Your HazCom 2012 Programm - Labeling HMIS label group is currently attempting to revise their system to be compliant NFPA?? 3-year window to see what type of workplace labeling systems are developed and decide which system to use Your HazCom 2012 Program - Labeling Secondary Containers: The employer is not required to label portable containers when hazardous chemicals are transferred from labeled containers and are intended only for the immediate use of the employee who performs the transfer 25

26 HazCom 2012 Summary Develop a written program describing how the standard elements are implemented Maintain a list of all hazardous chemicals. Obtain and make safety data sheets (SDS) available to employees SDS are the new MSDS SDS have 16 sections and a specific format for consistency of information Provide employees with training Address non-routine tasks. HazCom 2012 Summary Labeling on containers will now be required to have the following information: The product identifier (name) Signal word Hazard statements Pictograms Precautionary statements Name, address and telephone number of the chemical manufacturer, importer or other responsible party 26

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28 FAQ: English Only? Question: What languages do the labels have to be written in? For More FAQ: ov/dsg/hazcom/ind ex.html Answer: Labels.prominently displayed, and in English (other languages may also be included if appropriate). The chemical manufacturer or importer preparing the safety data sheet shall ensure that it is in English (although the employer may maintain copies in other languages as well), OSHA Website: Haz Com Page hazcom/index.html 28

29 Summary December 1, 2013: First Date for Employee Training Training Critical: In the language understood Documentation Important Eau Claire Appleton Madison Milwaukee 29

30 Wisconsin Compliance Assistance Specialists Kelly Bubolz Leslie Ptak U. S. Dept. of Labor - OSHA U. S. Dept. of Labor - OSHA 1648 Tri Park Way 4802 E. Broadway Appleton, WI Madison, WI (920) (608) Mary Bauer Jim Lutz U. S. Dept. Of Labor - OSHA U. S. Dept. of Labor - OSHA 1310 W. Clairemont Ave 310 W. Wisconsin Ave Eau Claire, WI Milwaukee, WI (715) (414)