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Update on the Implementation of the Globally Harmonized System of
Classification and Labeling of Chemicals (GHS) at the Hanford SiteRaja Atallah*, PhD, Mark Hermanson, and Pete Wells
Mission Support Alliance, Richland, WA
June 2015
GHS Introductory Video
Introduction
• OSHA Adopts GHS in March 2012
• OSHA Established an Implementation Timeline
• DOE Directed Mission Support Alliance (MSA) in June 2012 to Take the Lead for Hanford Implementation
• Hanford Inter-Contractor Work Group Established , June 2012
Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format.
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 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
Employers
Transition Period to the effective completion dates noted above
May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both
Chemical manufacturers, importers, distributors, and
employers
GHS Implementation Timeline
3-25-2012
12-1-2
013
6-1-
2015
12-1
-201
5
6-1-
2016
Implementation Process
• Training
• Hazard Container Labeling: Primary and Secondary
• Document Revisions: Chemical Management and HAZCOM Procedures
• Modified Data Bases
• Transition and Communication
Training Implementation at Hanford
• Worked with EFCOG on Developing Training
• Updated Hanford General Education Training (HGET), November 2012 (Video)
• Updated HAZCOM Section of the Hazardous Waste Operations and Emergency Response (HAZWOPER), Training, November 2012
• Developed Advanced GHS HAZCOM Training
• Updated the HAZCOM section for the Workers Basic HAZCOM Training
Hanford General Employee Training (HGET):
Hazardous Waste Operations and Emergency Response (HAZWOPER):
Basic HAZCOM Training
Site-Location Specific Training
Workers Training
Advanced GHS Training
• Provide in-depth training to professionals who will be advising workers or assisting with work planning
• Provide in-depth training to professionals who will be preparing and conducting GHS training to workers.
• Professionals attend the training
• Training duration four hours
Advanced GHS Training Course Outline
• Introduction to GHS
• Overview of the Revised HAZCOM Standard
• Summarize Criteria for Health, Physical and Environmental Hazard Classifications
• Discuss Elements of the GHS label and Safety Data Sheet
• Present Hanford Implementation of GHS: (Training, Labeling, Databases, Webpage, Document Revisions, Chemical Procurement Forms, Job Hazard Analysis)
• Discuss Changes Made or Anticipated by Other Organizations or Agencies
The Nature of Chemical Hazards
OSHA Defined & Listed Hazard Classes• Pyrophoric Gases• Combustible Dusts• Simple Asphyxiant• Hazards Not
Otherwise Classified
Globally Harmonized System (GHS)
GHS Poster
GHS Poster Example elements of the Standard
Health Hazards
Physical Hazards
GHS Poster Example elements of the Standard
OSHA Defined / Listed Hazards(Label Elements)
Hazard Class / Category Determination CriteriaOSHA - 29 CFR 1910.1200 Appendix A
Example Health Hazard: Acute Toxic (Oral, Dermal, Inhalation)
Hazard Class / Category Determination CriteriaUnited Nations GHS Standard (The Purple Book)
Example Health Hazard: Acute Toxic (Oral, Dermal, Inhalation)
Summary of Changes to HAZCOM Health Hazards
Summary of Changes to HAZCOM Health Hazards
Summary of Changes to HAZCOM Health Hazards
The GHS standard defines the label elements that must be placed on the primary (manufacturer’s) container. However, the GHS-HCS only established a general guideline for labeling the secondary (site repackaged) container. This guideline requires employers to use words, pictures, symbols, and other information to inform their employees on the physical and health hazards of the hazardous chemical.
Primary and Secondary GHS Labeling
GHS Manufacturer Label Elements Review
• Product Name/Identifier
• Pictogram(s)
• Signal Word
• Hazard Statements
• Precautionary Statements
• Supplementary Information
• Manufacturer Name and Emergency Contact
Workplace LabelingSecondary Container Labels
• Product Name/Identifier
• Pictogram
• Signal Word
• Hazard Statements
• Manufacturer Name
• Added Hanford GHS-SDS Number
• Removed Precautionary Statements
• Removed Manufacturer’s Emergency Contacts
• OSHA Requirements are Imprecise• Basic Content
• Hanford Workplace Labeling• Product & Manufacturer• Hanford Unique SDS Number• Color Coding• Signal Words and Pictograms• Hazard Statements• No Precautionary Statements• No NFPA 704 Hazard Ratings• The Value of Standardization• Possible Harsh Environments• EFCOG Best Practice
Radio Frequency Identification
Workplace LabelingSecondary Container Labels
NFPA-704 Hanford Hazard Container (HHC) Label
Flammability
Health Instability (Formerly Reactivity)
Specific Hazard:Oxidizer, (OX)
Water Reactive (W)
NFPA-704Degrees of Hazard 0-4
NFPA-704 (HHC) / GHS (HHC) Labels
Ammonium SulfamateJT Baker
Harmful if Swallowed
MakingSecondary Container Labels
None None
GHS (HHC) Label Variations
SDS and Secondary Label
The Best Practice on GHS compliant Hazard Label was awarded the 2015 EFCOG teamwork award for exceptional performance by a group of individuals who were instrumental in addressing a key EFCOG issue.
Mark Hermanson - MSAJeff Hieb - ATLMikhail Alnajjar - PNNLBruce Dickey - MSARaja Atallah - MSA
EFCOG Teamwork Award
Proposed Dates
Role Completed By
October 2014 Identify products that require secondary labels
(Facilities/CMSs)
January 2015 Worker training on new labels FEHIC Trainers
June 2015 Obtain SDSs for these products Facilities
June 2015 Review GHS-SDSs and provide labeling information
(IHs/HAZCOM-SME)
October 2015 Prepare labels at sign shop (Facilities/CMSs)
January 2016 Replace labels (Facilities/CMSs)
Hanford Implementation Plan - Labels
SDS-MSDS and CITS Databases
Chemical Inventory Tracking System
• Used by all Hanford Contractors for Inventory Tracking/Reporting• Product by Manufacturer• Identifies Constituents• NFPA Hazard Ratings• GHS Hazard Class, Category, and Statements
Safety Data Sheet – Material Safety Data Sheet
• Used by all Hanford Contractors for Basic Haz Com• All Current and Past SDS-MSDS Documents• Assigns a Hanford Unique SDS-MSDS Document Number• Distinguishes Between SDS and MSDS Formats• Product Name, Synonyms, Manufacturer, and Catalogue ID• SDS-MSDS Date
DATA
SDS – MSDS Database
Labeling MSDS and SDS Documents
CITS Database GHS Hazard Information Report
Required Changes to Procedures, Forms, Databases
HCS 1992 HCS –GHS 2012MSDS SDS
Flammable Liquids New criteria for flash points and boiling points
Combustible liquid Removed
Health Hazard Definitions (e.g. Sensitizer, Irritant , highly toxic)
Changed
Physical Hazard Definitions (e.g. Gases, )
Changed
Chemical Definition Changed to Substance
Examples of Procedures, Forms, and Databases
Document Examples
Procedures/Required Documentation/Plans/Guides
• Hazard Communication• Chemical Management• Occupational Carcinogen• Chemical Hygiene Plans• Hazard Analysis Documents
Databases • CITS• SDS/MSDS
Forms • MSA-CPS• MSA-CIW
Hanford’s GHS Web Page
Implementation Plan
Planned Action Implementation Process (Requirement)
Implementation Date and Status
Establishing Hanford GHS Working Group
Hanford contractors meet to coordinate actions and share ideas on the how to implement the revised standard. Members are made of training managers, HAZCOM subject matter experts, chemical management program personnel, industrial hygienists, CITS and SDS administrator. (Best Practice) DOE Letter of Direction to MSA, G. H. Branch/RL J. F. to Armijo/MSA Correspondence #1204857 A dated 11/05/2012.
Group meetings started in April 2012 and keep meeting per need at HAMMER Facility. See the GHS Web Page for meeting schedule, dates and minutes.
HAZCOM section part of Hanford General Employee Training (HGET)
Training material was revised by training managers and HAZCOM subject matter experts. The revised material included a GHS video and new slide on the new GHS elements. This training meets the OSHA requirements of providing workers initial GHS-HAZCOM training on the GHS elements by December 2013. (29CFR1910.1200 (j)(1) Effective Dates)
HGET is required annually for all Hanford employees. The new GHS HAZCOM part of HGET training was began November 2012 and completed by all Hanford employees by the OSHA deadline of December 2013. Training for new workers requires watching the five minutes GHS HAMMER video. Video is optional when retaking the training.
GHS Web Page Establish a web page to Announce available training and other activities; provide links to tools, resources, and related information; identify points of contact; and highlight communications.
GHS Web Page established May 2012 and is updated regularly.
Transition Communication
Comments / Questions