The Global Harmonized SystemGHSGHS

How do we do it??GASHE June Quarterly MeetingGASHE June Quarterly Meeting

Little Ocmulgee State Park LodgeLittle Ocmulgee State Park Lodge

Presented June 14, 2013By Ken Gregory CHSPBy Ken Gregory, CHSPTSIG Consulting, Inc

WHAT IS GLOBAL HARMONIZATION?

First you need to know what the Hazard Communication Standard (HCS) is.

In order to ensure chemical safety in the workplace, information about the identities and hazards of the chemicals must be available and understandableto workers. OSHA's Hazard Communication Standard (HCS) requires the ( ) qdevelopment and dissemination of such information: Chemical manufacturers and importers are required to evaluate the hazards of the

chemicals they produce or import, and prepare labels and safety data sheets to convey the hazard information to their downstream customers;

All employers with hazardous chemicals in their workplaces must have labels and safety All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train them to handle the chemicals appropriately.

A “Hazardous Chemical”, as defined by the Hazard Communication Standard (HCS), is any chemical which can cause a physical or a health hazardany chemical which can cause a physical or a health hazard.

WHAT IS GLOBAL HARMONIZATION?

In 2003, the United Nations (UN) adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) The GHS includes criteria for the Chemicals (GHS). The GHS includes criteria for the classification of health, physical and environmental hazards, as well as specifying what information should be included on labels of hazardous chemicals as well as safety data sheets. The United States was an active participant in the development of the GHS, and is a p p p ,member of the UN bodies established to maintain and coordinate implementation of the system.

AFFECTS

Occupational Safety and Health Administration (OSHA) Estimations

Employers/EmployeesOver 40 MILLION workersOver 5 MILLION workplacesOver 5 MILLION workplaces

$97 million in compliance cost per year

Benefits$ The revised standard will prevent 43 fatalities and 585 injuries and illnesses

annually.$ The annualized monetized benefits associated with these reductions in safety $ The annualized monetized benefits associated with these reductions in safety

and health risks are an estimated $266 million a year.$ Additional annualized benefits of $585 million a year from cost reductions and

productivity improvements attributable to the proposed revisions.$ In total, OSHA estimates that the proposed revisions will provide net $ , p p p

annualized savings of $754 million a year.

TIMELINE

OSHA published a Notice of Proposed Rulemaking to update the Hazard Communication Standard (HCS) in September 30 2009 (74 FR 50280 50549)September 30, 2009 (74 FR 50280-50549)

Public hearings were held in March 2010 The updating of the Hazard Communication standard The updating of the Hazard Communication standard

to align with the GHS finally became effective May 25, 2012

E l t t i l th l b l Employers must train employees on the new label elements and SDS format by December 1, 2013

TIMELINE

Chemical manufacturers, importers, distributors and employers must comply with all modified provisions of this final rule by December 1 2016 except:this final rule by December 1, 2016, except:

Distributors may ship products labeled by manufacturers under the old system until December 1 2015until December 1, 2015.

Employers must update alternative workplace labeling and hazard communication program as necessary,

d id dditi l l t i i g f l and provide additional employee training for newly identified physical or health hazards by June 1, 2016

GHS

Pl i E gli h Pl D !!Plain English Please Doc!! Currently OSHA requires Employers to comply

with the Code of Federal Regulations (CFR) with the Code of Federal Regulations (CFR) requirement 29 CFR Parts 1910, 1915, 1917, 1918, and 1926 called the “Hazardous Communication Standard”

The HazCom Standard requires employers to warn employees about potential dangers warn employees about potential dangers associated with chemicals in THEIR workplace

This is why we have labeling for chemicals, This is why we have labeling for chemicals, MSDS documents, manifests, etc.

GHS

Pl i E li h Pl D !!Plain English Please Doc!!

What this GHS process has done is taken the old HazCom program, written in 1994, and edited it to be more aligned with the United Nations in order to make information universal

GHS

Wh did OSHA li h HCS i h GHS?Why did OSHA align the HCS with GHS?

Harmonized definitions of hazards Specific criteria for labels Harmonized format for safety data sheets

GHS

B fit f Ad ti g th GHSBenefits of Adopting the GHS Increase the quality and consistency of information

provided to the workers employers and chemical provided to the workers, employers and chemical users.Reduce confusion/Increase comprehension of

hazards. Improve downstream risk management.Facilitate trainingFacilitate training.Help address literacy problems.

Other benefits include facilitation of international trade in chemicals.

GHS

S N i bl ChSome Noticeable Changes Labels are more defined and will now require:

» Product identifier» Pictogram

Signal ord» Signal word» Hazard statement(s)» Precautionary statement(s)» Precautionary statement(s)» Name, address, and telephone number

“Safety data sheet” (rather than “material safety Safety data sheet (rather than material safety data sheet”) uses a 16-section format

GHS

Product identifier: How the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS (Identification) 1 of the SDS (Identification).

GHS

Signal word: Used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. There are only two signal words, “Danger” and “Warning.” Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. There will only be one signal word on the label no matter how e e o y be o e s g a o d o t e abe o atte omany hazards a chemical may have. If one of the hazards warrants a “Danger” signal word and another warrants the signal word “Warning ” then only “Danger” should appear on signal word Warning, then only Danger should appear on the label.

GHS

Pictogram: gOSHA’s required pictograms must be in the shape of a square set at a point and include a black hazard symbol on

hit b k d ith d f ffi i tl id a white background with a red frame sufficiently wide enough to be clearly visible. A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label. OSHA has designated eight pictograms under this standard for application to a hazard categorycategory.

GHS

Hazard statement(s): Describe the nature of the hazard(s) of a chemical, including, ( ) , g,where appropriate, the degree of hazard. For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.” All of the applicable hazard absorbed through the skin. All of the applicable hazard statements must appear on the label. Hazard statements may be combined where appropriate to reduce redundancies and improve readability. The hazard statements are specific to the improve readability. The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces itwhat the chemical is or who produces it.

GHS

Precautionary statement(s): Precautionary statement(s): Means a phrase that describes recommended measures that should be taken to minimize or measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.

GHS

Name address and phone number of the Name, address and phone number of the chemical manufacturer, distributor, or importer

GHS

GHSExplain how you can use the labels in the workplace. For example, Explain how information on the label can be used to ensure

proper storage of hazardous chemicals. Explain how the information on the label might be used to p g

quickly locate information on first aid when needed by employees or emergency personnel.

Provide a general understanding of how the elements g gwork together on a label. For example, Explain that where a chemical has multiple hazards,

different pictograms are used to identify the various p g yhazards. The employee should expect to see the appropriate pictogram for the corresponding hazard class.

Explain that when there are similar precautionary p p ystatements, the one providing the most protective information will be included on the label.

GHS

Training on the format of the SDS must include Training on the format of the SDS must include information on: Standardized 16-section format, including the type of

information found in the various sections For example, the employee should be instructed that with the

new format, Section 8 (Exposure Controls/Personal Protection) ill l t i i f ti b t li it will always contain information about exposure limits,

engineering controls and ways to protect yourself, including personal protective equipment.

Instruct how the information on the label is Instruct how the information on the label is related to the SDS For example, explain that the precautionary statements y

would be the same on the label and on the SDS.

GHS

16-Section Safety Data Sheet16 Section Safety Data Sheet

1. Identification of the substanceor mixture and of the supplier

11. Toxicological 12. Ecological information

2. Hazards identification3. Composition/information on

ingredients Substance/Mixture

g(non mandatory)

13. Disposal considerations(non mandatory)

4. First aid measures 5. Firefighting measures6. Accidental release measures7 H dli d t

14. Transport information(non mandatory)

15. Regulatory information(non mandatory)7. Handling and storage

8. Exposure controls/personal protection

9 Physical and chemical properties

(non mandatory)16. Other information including

information on preparation and revision of the SDS

9. Physical and chemical properties10. Stability and reactivity

MORE INFORMATIONMORE INFORMATION

HazCom 2012 Webpagehttp://www osha gov/dsg/hazcom/index htmlhttp://www.osha.gov/dsg/hazcom/index.html

S f t & H lth T i W bSafety & Health Topics Webpagehttp://www.osha.gov/dsg/hazcom/index2.html

MORE INFORMATIONMORE INFORMATION

OSHA’s Hazard Communication website (http://www.osha.gov/dsg/hazcom/index.html) has th f ll i Q i kC d d OSHA B i f tthe following QuickCards and OSHA Briefs to assist employers with the required training.

• Label QuickCard (English/Spanish)• Pictogram QuickCard (English/Spanish)• Safety Data Sheet QuickCard (English) (Spanish)• Safety Data Sheet OSHA Brief• Label/Pictogram OSHA Brief (to come)g ( )

SUMMARYSUMMARY

It’s OSHA Boys and GirlsDon’t miss the dates!!!

THE GOVERNMENT NEEDS THE MONEY!

QUESTIONS

Ken Gregory, CHSP

Vice President – South AtlanticTSIG C ltiTSIG Consulting740 Broadway

New York NY 10003New York, NY 10003(615) 598-2652

gregoryk@tsigconsulting.comg g y @ g g