Bernadette Lindquist, PhD, DABT, Ashland Inc. Keith Silverman, PhD, MPH, Ashland Inc. and National TRANSCAER Task Group

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1 HazCom 2012: helping to make the world smaller for first responders OSHA s Adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Bernadette Lindquist, PhD, DABT, Ashland Inc. Keith Silverman, PhD, MPH, Ashland Inc. and National TRANSCAER Task Group The United Nations (UN) has long recognized that a common approach for classifying and communicating chemical hazards would serve as the foundation for effective national chemical hazard communication programs across the globe. Thus, an international mandate for development of a harmonized system for the classification and labeling of chemicals was adopted at the United Nations Conference on the Environment and Development (UNCED), the Earth Summit, held in Brazil in The system, the GHS, was to include a coherent approach to defining and classifying hazards of chemicals, and a method for communicating such information on labels and in safety data sheets (SDS), including easily understandable symbols. In 2002, a UN committee of experts approved the first version of the GHS (the Purple Book ) and the GHS has been available for implementation since The GHS is revised every two years with the fifth revised edition to be released in OSHA implemented the third revised edition of the GHS in 2012 in its revision of the Hazard Communication Standard, now known as "HazCom 2012." The basic scope and application of the OSHA Hazard Communication Standard has not changed under HazCom Chemical manufacturers are still required to evaluate the chemical hazards of chemicals they produce and to relay such information to customers in the form of SDS and labels. Employers with hazardous chemicals in their workplaces must still have SDS and labels for their exposed workers, and must ensure that workers are trained on handling these chemicals appropriately. HazCom 2012 adds specific criteria for chemical classification, requires prescriptive elements for chemical labels, specifies a 16- section SDS, and requires worker training on these new hazard communication elements. Chemical Classification The GHS includes schemes for classifying chemicals with respect to physical, health and environmental hazards, as well as methods for classifying mixtures. The term "chemical" in the GHS is used very broadly to include chemicals and chemical products, both as individual chemicals and as mixtures. Under GHS, chemicals are classified with respect to various hazard endpoints, known as hazard classes. Physical hazard classification incorporates criteria for classifying chemicals with respect to explosivity, flammability, and reactivity, for example. GHS health hazard endpoints include: skin and eye irritation/corrosivity, acute and chronic toxicity (toxicity from short- and long-term exposure, respectively), ability to induce an allergic reaction, potential to cause cancer or developmental

2 effects, and others. The UN GHS also provides a classification scheme for classifying chemicals with respect to short- and long-term effects on the environment. Environmental hazards are not regulated under OSHA; therefore the environmental classification scheme is not part of HazCom These environmental effects are currently limited to hazardous effects on the aquatic environment and to the ozone layer. While not a regulatory requirement under OSHA, some chemical manufacturers/distributors may choose to classify their chemicals with respect to environmental hazard, especially if the data is already available in order to comply with GHS outside the US. Within each of the physical, health and environment hazard classes are a number of hazard categories (there may be one to seven categories per hazard class) into which a chemical may be classified. Certain of these categories are composed of optional sub-categories that may be implemented at the discretion of the regulatory authority. These hazard categories reflect the severity of hazard. Classification in a given category is based upon whether or not a chemical meets the classification criteria associated with that category. Classification is based upon available data for the chemical. HazCom 2012 itself does not require testing. When classifying mixtures, GHS principles, under some circumstances, allows for use of data from similar mixtures and data from components in a mixture. Within each hazard class, the hazard categories can be viewed as the building blocks of the GHS (Figure 1). Figure 1 2

3 The GHS incorporates a building block approach through which a regulatory scheme can be developed by a national regulatory authority based upon the needs of the target audience for that information. The lack of inclusion of environmental classification under HazCom 2012 is an example of a regulatory authority applying the building block approach. To further illustrate the building block approach, consider, for example, the transportation sector. This sector focuses on classification and labeling elements for acute and physical hazards only, and does not currently classify with respect to chronic hazards. Thus the transportation authorities have not adopted the building blocks related to chronic health hazards. Another aspect of the building block approach is the option of not adopting all of the categories within a given hazard class. That is, a regulatory authority may choose to regulate some, but not all, of the hazard categories within a class. The most severe hazard category within a class must be adopted if that class is regulated by a given regulatory authority. For example, if flammable liquids are regulated, Category 1 (the most severe classification) must be adopted. The remaining adopted categories must form an unbroken sequence. Specific criteria are used to define the hazard categories, for example: Flammable liquids classification criteria Category 1: Flash point <23ºC and initial boiling point 35 ºC Category 2: Flash point <23ºC and initial boiling point >35 ºC Category 3: Flash point 23ºC and 60 ºC Category 4: Flash point >60ºC and 93 ºC Unlike OSHA which has adopted all four categories of flammable liquids, certain regulatory authorities, including the European Commission, have chosen not to adopt Category 4 for flammable liquids. Thus, the building block approach results in certain chemicals (Category 4) being regulated as flammable liquids in some, but not all, countries/regions, and in general, leads to a lack of harmony among GHS implementations across the globe. Under HazCom 2012, OSHA has included several hazard classes that are covered under the previous Hazard Communication Standard, but that have not been addressed in the UN GHS: Pyrophoric gases and simple asphyxiants o Hazards must be addressed on both labels and SDS. o Definition of hazards and standardized hazard communication elements are provided in HazCom

4 Combustible dust o Hazards must be addressed on both labels and SDS. o Classification criteria are not provided in HazCom 2012, though reference is made to existing OSHA documents and to voluntary industry consensus standards. o Some flexibility in labeling is allowed for chemicals in solid form that do not present a combustible hazard as shipped, but may form combustible dust during processing by downstream users. Hazards Not Otherwise Classified (HNOC) any adverse physical or health effect identified through evaluation of scientific evidence during the classification process that does not meet criteria specified elsewhere in the standard o Requires information on the hazard in Section 2 of the SDS. o Has no specific labeling requirements. o Was included by OSHA to prevent any hazard covered under the previous Hazard Communication Standard from being excluded under HazCom Hazard Communication Despite regulatory authority implementation options, use of the GHS worldwide will minimize differences, not only in the way chemicals are classified around the globe, but also in the way that hazards of chemicals are communicated. It is the ultimate goal of the UN that use of a consistent and easily understandable hazard communication scheme will enhance protection of human health and the environment. Each GHS hazard category (example: Categories 1 for flammable liquids) within a given hazard class (example: flammable liquids) associates with standardized labeling elements: pictograms, signal words; and hazard phrases (see examples in Figures 2 and 3), as well as precautionary phrases that relate to safe handling, storage, emergency response and disposal. (Precautionary phrases are not fully harmonized.) As shown in Figures 2 and 3, a chemical classified as a Category 3 Flammable Liquid under HazCom 2012, for example, must have a flame pictogram, a signal word Warning and the hazard phrase Flammable liquid and vapor. While there is no Combustible liquid classification, per se, a chemical classified as a Category 4 Flammable Liquid would require the hazard phrase Combustible liquid, but no pictogram. 4

5 Figure 2 Hazard Class Hazard Category Pictogram FLAMMABLE LIQUIDS Category 1 Category 2 Category 3 Category 4 No pictogram Signal Word Danger Danger Warning Warning Hazard Phrase Extremely flammable liquid and vapor Highly flammable liquid and vapor Flammable liquid and vapor Combustible liquid Figure 3 5

6 Standardized Labeling Elements GHS pictograms are composed of black symbols on a white background with a red diamond frame. Within a GHS implementation, regulatory authorities are given freedom to allow black borders for domestic shipments; OSHA requires red borders for all labeled containers, including domestic, however. Of the eight OSHA HazCom 2012 symbols, six are standard symbols used in the UN recommendations on the Transport of Dangerous Goods, Model Regulations. Two new health symbols are introduced in the GHS (and in HazCom 2012): the Exclamation Mark and the Health Hazard symbols, as shown in Figure 4. Figure 4 The exclamation mark is used to draw attention for less severe adverse health effects that may result from short-term exposure, e.g. eye or skin irritation, or skin sensitization, while the health hazard symbol is used for more severe hazards such as respiratory sensitization, aspiration hazard, and hazards resulting from chronic exposure, e.g. reproductive toxicity and carcinogenicity. Two signal words are used in HazCom 2012 to alert users of potential hazards: Danger and Warning. Danger is used for the more severe and Warning for the less severe hazard categories. Standardized hazard phrases are used to describe chemical hazards, and where appropriate, the degree of severity of hazards. Standardized precautionary phrases are used to describe recommended measures to be taken for minimization or prevention of adverse effects resulting from exposure to, and from improper storage and handling of, hazardous chemicals. There are four types of precautionary phrases including: 1) preventive information, e.g. special 6

7 handling instructions, 2) response information, e.g. first aid measures and instructions in case of a spill or fire involving the chemical, 3) storage recommendations, and 4) information on disposal of the chemical. While standardized hazard phrases associated with GHS categories should not be subject to variation, assignment of precautionary phrases requires professional judgment and there is some flexibility allowed in assignment of these phrases. A precautionary phrase associated with a given hazard category can be omitted, for example, if the chemical manufacturer, importer, or responsible party can demonstrate that the information is inappropriate for the chemical product being labeled. HazCom 2012 Implementation Deadlines OSHA maintains a Hazard Communication webpage that summarizes key features of HazCom 2012, including important implementation deadlines. The requirement for training employees on the new label elements and on the changes to the SDS format is December 1, Compliance with most other provisions of the rule must be in place by June 1, Distributors may continue to distribute chemicals with non-ghs labels until December 1, During the transition period, both GHS and legacy OSHA labels will be seen in facilities in the United States. The deadline for updating alternate workplace labeling, other updates to hazard communication programs, and additional employee training with respect to newly identified physical or health hazards must be completed by June 1, DOT, NFPA and HMIS Labeling For hazards regulated under transport, the U.S. Department of Transportation (DOT) has aligned its classification criteria with the GHS/HazCom 2012 for hazards other than environmental. Thus transport and hazard communication labeling elements will be consistent with each other with respect to physical and health hazards, recognizing that the transportation sector does not label for all health hazards. DOT allows labelers to utilize GHS criteria for environmental labeling, so there may or may not be differences in environmental labeling for a given chemical. Both NFPA (National Fire Protection Association) and ACA s HMIS (American Coatings Association s Hazardous Materials Information System) workplace labels are frequently seen in U.S. workplaces. Both systems are geared toward simple and rapid recognition of chemical hazards, with the NFPA hazard diamond directed at emergency responders and the HMIS label targeted toward employees who work with chemicals. It s important to note that numerical rating schemes do not align between NFPA or HMIS and OSHA HazCom 2012, nor do the classification criteria align among the systems. Under NFPA 704 and HMIS, a 0 indicates the least severe hazard condition, with 4 being the most hazardous rating, whereas the most severe hazard in a given HazCom 7

8 2012 hazard class is 1. The NFPA and OSHA are working together to consider whether changes to the current NFPA 704 labeling scheme are warranted based on the revised OSHA standard. The ACA is in the process of preparing compliance guidance for users of the HMIS system. User training is critical for users of both systems, particularly in light of changes related to HazCom There has been concern in the emergency response community that the numerical rating schemes do not align between NFPA and OSHA HazCom Therefore, it is important to point out that the new HazCom 2012 labels will not include the hazard category number nor will it appear under or inside the pictograms. The HazCom 2012 hazard category numbers will only appear in the supporting information provided in the SDS. An emergency responder looking at a container may see the familiar NFPA 704 diamond as well as the familiar transportation labels in addition to the new HazCom 2012 label. Since the HazCom 2012 hazard category numbers are not required on the container label, the potential for creating confusion during the initial stages of an emergency will be minimized. The emergency responder tasked with doing research on the chemical will need to be familiar with the differences between HazCom 2012 and NFPA 704. Therefore, training in and familiarity with all container labeling systems is a key skill for emergency responders. Global Implementation of the GHS The GHS is bringing global change in the way chemical hazards are classified and communicated. Since it became available for implementation in 2003, many countries/regions have adopted this classification and labeling approach into their national legislation while many others are in various stages of GHS adoption, from doing impact and cost/benefit analysis to drafting/proposing new national regulations. Proper assessment of chemical hazards and presentation of hazard information clearly and consistently across all sectors and in all parts of the globe is expected to contribute to safer use, transport, and disposal of chemicals, and ultimately lead to enhanced protection of human health and the environment. Preparing for HazCom2012 As mentioned above, Hazcom 2012 will be phased in over the next few years, with full compliance scheduled for The requirement for training employees on the new label elements and on the changes to the SDS format is December 1, Emergency response organizations will benefit from early training of first responders since the new HazCom 2012 standard can already be found in the workplace on container labels and in SDSs. The target audience for HazCom 2012 and GHS awareness training is first responders, HazMat teams, safety managers, local emergency planning committees, and public safety agencies. At 8

9 a minimum, the training should provide responders with an awareness of the following: Hazard classes including pyrophoric gases, simple asphyxiants, combustible dust, and hazards not otherwise classified. 8 pictograms, including the two new health symbols: the Exclamation Mark and the Health Hazard. Hazard statements and precautionary statements. Differences between the hazard category numbers in HazCom 2012 and the NFPA 704 and HMIS systems. New SDS format. New HazCom 2012 container label format. The international effort to provide global consistency to the classification and labeling of hazardous chemicals using GHS has been underway for several years. The efforts so far have done a lot to make the world a smaller place and we are closer now to a globally harmonized system than we have ever been in the past. Going forward, emergency responders will gain valuable experience with GHS and will learn the best way to use the new system as an aid during both pre-emergency planning and during emergencies. For now, let s spread the word and focus our efforts on training our emergency responders. 9