osha update revised hazard communication (ghs) · 2017-10-06 · 1 osha update and the revised...
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1
OSHA Update
and the
Revised Hazard Communication
Standard
(GHS)
Triumvirate Environmental
OSHA Update
Top 10 Violations
1926.451 – Scaffolding
1926.501 – Fall
Protection
1910.1200 – Hazard
Communication
1910.134 – Respiratory
Protection
1910.147 –
Lockout/Tagout
1910.305 – Electrical,
Wiring Methods
1910.178 – Powered
Industrial Trucks
1926.1053 – Ladders
1910.303 – Electrical,
General Requirements
1910.212 – Machine
Guarding
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Updates
Heat Campaign
Residential Falls
Needle sticks
Teen Workers Fed & State
Hearing Loss
Emergency Action Plans
Machine guarding
Laser Safety
Electrical Training & Equipment
Powered Industrial Trucks
Languages
Emphasis NEP, LEP, SST
Hazcom
National Campaigns
Heat
Residential Falls
Roll Outs Ladder Safety
Electric Cords
Needle Sticks
Needle sticks
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Safer Needles
Training,
Training,
Training,
http:www.osha.gov to Young Workers
Young Workers
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Young – Teen Workers
Hearing
Hearing Loss Whaaat ?
Hearing Protection
Quiz:
Action Level = ___ dB
PEL = ___ dB
STEL = ___ dB x ___
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Emergency Action Plans
1910.38(a) Application. An employer must have an emergency action plan whenever an OSHA standard in this part requires one.
The requirements in this section apply to each such emergency action plan.
1910.38(b) Written and oral emergency action plans. An emergency action plan must be in writing, kept in the workplace, and
available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to
employees.
1910.38(c) Minimum elements of an emergency action plan. An emergency action plan must include at a minimum:
1910.38(c)(1) Procedures for reporting a fire or other emergency;
..1910.38 (c)(2)
1910.38(c)(2) Procedures for emergency evacuation, including type of evacuation and exit route assignments;
1910.38(c)(3) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate;
1910.38(c)(4) Procedures to account for all employees after evacuation;
1910.38(c)(5) Procedures to be followed by employees performing rescue or medical duties; and
1910.38(c)(6) The name or job title of every employee who may be contacted by employees who need more information about
the plan or an explanation of their duties under the plan.
1910.38(d) Employee alarm system. An employer must have and maintain an employee alarm system. The employee alarm
system must use a distinctive signal for each purpose and comply with the requirements in § 1910.165.
1910.38(e) Training. An employer must designate and train employees to assist in a safe and orderly evacuation of other
employees.
1910.38(f) Review of emergency action plan. An employer must review the emergency action plan with each employee covered by the plan:
1910.38(f)(1) When the plan is developed or the employee is assigned initially to a job;
1910.38(f)(2) When the employee's responsibilities under the plan change; and
1910.38(f)(3)
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Emergency Action Plans
Emergency Action Plan must be in writing, onsite
Procedures for reporting a fire or other emergency
Evacuation, type of evacuation and exit route assignments
Employees who remain
Account for all employees after evacuation
Employees performing rescue or medical duties
Name employees for more information contact
Employee alarm system; have, maintain; distinctive signal, each purpose
Designate and train each employee assisting evacuation
Review EAP with each covered employee
§ 1910. 157 Fire Brigades 1910. 165 Employee Alarm Systems
1910. 120(q) Hazwoper – Emergency Response NFPA
Other Regulations……
1910. 157 Fire Brigades
1910. 165 Employee Alarm Systems
1910. 120(q) Hazwoper – Emergency Response
NFPA
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Guarding & Electrical
Machine guarding
Hazard Analysis
Manufacturer
Nationally Recognized Standards
Electrical T raining
E quipment <Rated>
D ocumentation
D isciplinary Program <Positive , Progressive, >
Practices L O T O
Lasers Types
Laser Safety
Types of Lasers
There are many different types of lasers. The laser medium can be a solid, gas, liquid or semiconductor.
Lasers are commonly designated by the type of lasing material employed:
Solid-state lasers have lasing material distributed in a solid matrix (such as the ruby or neodymium:yttrium-
aluminum garnet "Yag" lasers). The neodymium-Yag laser emits infrared light at 1,064 nanometers (nm). A
nanometer is 1x10-9 meters.
Gas lasers (helium and helium-neon, HeNe, are the most common gas lasers) have a primary output of visible
red light. CO2 lasers emit energy in the far-infrared, and are used for cutting hard materials.
Excimer lasers (the name is derived from the terms excited and dimers) use reactive gases, such as chlorine
and fluorine, mixed with inert gases such as argon, krypton or xenon. When electrically stimulated, a pseudo
molecule (dimer) is produced. When lased, the dimer produces light in the ultraviolet range.
Dye lasers use complex organic dyes, such as rhodamine 6G, in liquid solution or suspension as lasing
media. They are tunable over a broad range of wavelengths.
Semiconductor lasers, sometimes called diode lasers, are not solid-state lasers. These electronic devices are
generally very small and use low power. They may be built into larger arrays, such as the writing source in
some laser printers or CD players.
Lasers- Classes
Class I: cannot emit laser radiation at known hazard levels (typically continuous wave: cw 0.4 µW at visible
wavelengths). Users of Class I laser products are generally exempt from radiation hazard controls during
operation and maintenance (but not necessarily during service).
Since lasers are not classified on beam access during service, most Class I industrial lasers will consist of a
higher class (high power) laser enclosed in a properly interlocked and labeled protective enclosure. In some
cases, the enclosure may be a room (walk-in protective housing) which requires a means to prevent operation
when operators are inside the room.
Class I.A.: a special designation that is based upon a 1000-second exposure and applies only to lasers that are
"not intended for viewing" such as a supermarket laser scanner. The upper power limit of Class I.A. is 4.0 mW.
The emission from a Class I.A. laser is defined such that the emission does not exceed the Class I limit for an
emission duration of 1000 seconds.
Class II: low-power visible lasers that emit above Class I levels but at a radiant power not above 1 mW. The
concept is that the human aversion reaction to bright light will protect a person. Only limited controls are
specified.
Class IIIA: intermediate power lasers (cw: 1-5 mW). Only hazardous for intrabeam viewing. Some limited controls
are usually recommended.
NOTE: There are different logotype labeling requirements for Class IIIA lasers with a beam irradiance that does
not exceed 2.5 mW/cm2 (Caution logotype) and those where the beam irradiance does exceed 2.5 mW/cm2
(Danger logotype).
Class IIIB: moderate power lasers (cw: 5-500 mW, pulsed: 10 J/cm2 or the diffuse reflection limit, whichever is
lower). In general Class IIIB lasers will not be a fire hazard, nor are they generally capable of producing a
hazardous diffuse reflection. Specific controls are recommended.
Class IV: High power lasers (cw: 500 mW, pulsed: 10 J/cm2 or the diffuse reflection limit) are hazardous to view
under any condition (directly or diffusely scattered) and are a potential fire hazard and a skin hazard. Significant
controls are required of Class IV laser facilities.
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Lasers
Directive Brief Overview Directive Number: TED 01-00-015
Effective Date: 1/20/1999
Introduction
Nonbeam Laser Hazards
Biological Effects of the Laser Beam
Laser Hazard Classifications
Investigational Guidelines
Control Measures and Safety Programs
Bibliography
→Controls
» Engineering controls
» Personal Protective Equipment
» Administrative
» Procedural controls
» Special controls
Lasers – VI. Control Measures and
Safety Programs
ANSI Z 136.1 (1993): FOR THE SAFE USE OF LASERS
ANSI Z 136.3 (1988): "FOR THE SAFE USE OF LASERS IN HEALTH CARE FACILITIES"
ANSI/NFPA 70-1990: THE NATIONAL ELECTRICAL CODE - 1990 HANDBOOK
ANSI Z 87.1 (1989): "PRACTICE FOR OCCUPATIONAL AND EDUCATIONAL EYE AND FACE PROTECTION"
A. CLASS I, CLASS II, CLASS I.A., AND CLASS IIIA LASERS.
B. LASER SAFETY OFFICER (LSO).
C. BEAM PATH CONTROLS
D. LASER-CONTROLLED AREA
E. CLASS IV LASER CONTROLS--GENERAL REQUIREMENTS.
F. ENTRYWAY CONTROL MEASURES (CLASS IV)
G. TEMPORARY LASER-CONTROLLED AREA.
H. ADMINISTRATIVE AND PROCEDURAL CONTROLS
I. ENGINEERING CONTROLS
J. LASER USE WITHOUT PROTECTIVE HOUSING (ALL CLASSES)
H. OPTICAL FIBER (LIGHT WAVE) COMMUNICATION SYSTEMS (OFCS)
Lasers - Signs
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Lasers
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2
P I T s
Powered Industrial Trucks
T raining
E quipment
D ocumentation
D iscipline *
Special Programs
Emphasis Examples
NEP Dust
LEP Falls/MAST Climbers
SST Fishing Industry
UTenn <Dodge> Random
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Language
Languages
Spanish
Portuguese
Vietnamese
Other
Communication
Training
Qualification
Understanding
Language Initiatives
Language Target Groups
Channel
Portuguese Alliance Groups
Spanish Community
Vietnamese Consulates
Other(s) Trades
Schools
Youth Work Sites
Social Media
·
Analyze
Applicable issues – Methods to Resolve
Let’s look at . . .
Top 10 Violations
CAS Activities
Pathways to Success . . . <all paid for>
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Let’s Take a Short Break!
Revised Hazard Communication
Standard
Why is GHS Needed?
No country has the ability to identify and
specifically regulate every hazardous
chemical product
For example, in the United States, there
are an estimated 945,000 such products
Adoption of requirements for information
to accompany the product helps address
protection needs
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Why is GHS Needed? (cont.)
Countries with systems that address
these needs have adopted different
requirements for hazard definitions as
well as information to be included on a
label or material safety data sheet.
This impacts both protection and trade.
An estimated 41 million employees are
potentially exposed to hazards
chemicals
Why Does OSHA want this?
OSHA's Hazard Communication Standard
(HCS) has performance-oriented
requirements for labels and safety data
sheets
Hazard communication is often
inconsistent as a result
Users of labels and safety data sheets
would prefer a standardized approach
Adoption of the GHS would address this
domestic concern
Major Revisions to the HCS
Hazard Classification – Provides specific
criteria for classification of health and
physical hazards, as well as classification
of mixtures and chemicals
Labels – Chemical manufactures and
importers will be required to provide a label
that includes a harmonized signal word,
pictogram, and hazard statement for each
hazard class and category. Precautionary
statements must also be provided.
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Major Revisions to the HCS
Safety Data Sheets – Will now be
required to be in the 16 part format
Information and Training – All
employers are required to train
workers on the new labels, elements
and safety data sheets format
Refined definitions of Flammable
Liquids and Toxicity
What is the primary benefit?
The primary benefit of the revised standard
is to increase the quality and consistency of
information provided to workers, employers
and chemical users by adopting a
standardized approach to hazard
classification, labels and safety data.
Estimated to prevent 43 fatalities and 521
injuries and illness per year.
What are the primary benefits?
OSHA estimates that the monetized health
and safety benefits of the final rule are $250
million annually and that the annualized
cost reductions and productivity gains are
$507 million annually.
The revised standard provides a single set
of harmonized criteria for classifying
chemicals according to their health and
physical hazards
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What are some key terms in the
Revised Standard?
SDS - Safety Data Sheet. SDS is the term
used by GHS for Material Safety Data Sheet
(MSDS).
Hazard Category – These categories
compare hazard severity within a hazard
class
Classification - is the term used to describe
the different hazards.
What are some key terms in the
GHS Vocabulary?
Hazard Statement - For each category of a
class, a standardized statement is used to
describe the hazard. The hazard statement
would appear both on the label and on the
SDS.
Signal word - There are two signal words in
the GHS system - Danger and Warning.
There are categories where no signal word
is used.
What are some key terms in the GHS
Vocabulary?
Pictogram - Pictogram refers to the GHS
symbol on the label and SDS. Not all
categories have a symbol associated with
them.
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New – Flammable Liquid
OSHA deleted the term “Combustible
Liquid”
Flammable liquid means any liquid having a
flashpoint at or below 199.4 [deg]F (93
[deg]C).
New Flammable Liquid
Flammable liquids are divided into four
categories as follows: Category 1 shall include liquids having flashpoints below 73.4F
and boiling point at or below 95F.
Category 2 shall include liquids having flashpoints below 73.4F
and a boiling point above 95F
Category 3 shall include liquids having flashpoints at or above
73.4 F and at or below 140F.
Category 4 shall include liquids having flashpoints above 140F
and at or below 199.4F
Flammable Liquid Storage
Container
Type
Category 1 Category 2
Category 3
Category 4
Glass or
Approved
Plastic
1 pint 1 quart 1 gallon 1 gallon
Metal (other
than DOT
drums)
1 gallon 5 gallons 5 gallons 5 gallons
Safety Cans 2 gallons 5 gallons 5 gallons 5 gallons
Metal Drums
(DOT
approved)
60 gallons 60 gallons 60 gallons 60 gallons
Approved
Portable Tanks
660 gallons 660 gallons 660 gallons 660 gallons
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What are the classes within the
Health hazard group?
Acute toxicity
Skin corrosion/irritation
Serious eye
damage/eye irritation
Respiratory or skin
sensitization
Germ cell mutagenicity
Aspiration hazard
Carcinogenicity
Reproductive toxicity
Specific target organ
toxicity - single
exposure
Specific target organ
toxicity - repeated
exposure, and
What are the classes within the
Physical hazard group?
Explosives
Flammable gases/aerosols
Oxidizing gases
Gases under pressure
Flammable liquids/solids
Self-reactive substances
and mixtures
Corrosive to metals
Pyrophoric
liquids/Solids
Self-heating substances
and mixtures
Substances and
mixtures which, in
contact with water, emit
flammable gases
Oxidizing liquids/Solids
Organic peroxides
Example Labels
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Flammable Liquid
•Flammables
•Pyrophorics
•Self-Heating
•Emits Flammable Gas
•Self-Reactives
•Organic Peroxides
Exploding Bomb
•Explosives
•Self-Reactives
•Organic Peroxides
Corrosive
•Skin Corrosion/Burns
•Eye Damage
•Corrosive to Metals
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Irritant
•Irritant (skin and eye)
•Skin Sensitizer
•Acute Toxicity
•Narcotic Effects
•Respiratory Tract Irritant
•Hazardous to Ozone Layer
(Non-Mandatory)
Flame Over Circle
•Oxidizers
Gas Cylinders
•Gases Under Pressure
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Skull and Crossbones
•Acute Toxicity (fatal or toxic)
Health Hazard
•Carcinogen
•Mutagenicity
•Reproductive Toxicity
•Respiratory Sensitizer
•Target Organ Toxicity
•Aspiration Toxicity
Environment (Non-Mandatory)
•AQUATIC TOXICITY
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Signal Words
Signal Words
The final rules requires the use of only two
signal words for labels
»Danger
»Warning
Danger is used for the more sever hazards
Warning denotes less of a hazard
Regulated Chemicals Signal Words
OSHA has revised the regulated signage for
substance specific health standard
materials
These include, but are not limited to the
following materials: Asbestos
Lead
Cadmium
Ethylene Oxide
Formaldehyde
Benzene
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Safety Date Sheets
Safety Data Sheets
The safety data sheet should provide
comprehensive information about the
chemical that allows employers and
workers to obtain concise, relevant and
accurate information that can be put in
perspective with regard to the hazards,
uses and risk management of the chemical
product in the workplace.
Safety Data Sheets
The SDS must contain 16 sections. While
there were some differences in existing
industry recommendations, and
requirements of countries, there was
widespread agreement on a 16 section SDS
that includes the following headings in the
order specified:
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Safety Data Sheets
Identification
Hazard(s) identification
Composition/ information
on ingredients
First-aid measures
Fire-fighting measures
Accidental Release
Measures
Handling and storage
Transport information
Regulatory information
Handling and storage
Exposure control/ personal
protection
Physical and chemical
properties
Stability and reactivity
Toxicological information
Ecological information
Disposal considerations
Transport information
Regulatory information
Other information.
Hazard and Precautionary
Statements
Hazard and Precautionary Statements
Hazard Statements describe the
hazards associated with a
chemical
Precautionary Statements describe
recommended measures that
should be taken to protect against
hazardous exposures, or improper
storage or handling of a chemical
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Hazard and Precautionary Statements
OSHA has stated that standardizing
the requirements for hazard and
precautionary statements will provide
a degree of consistency that is lacking
among the current chemical labels.
Example New Posting for
Formaldehyde
DANGER
Formaldehyde
Irritant and
Potential Cancer
Hazard
Authorized
Personnel Only
DANGER
Formaldehyde
May Cause Cancer
Causes Skin, Eye,
and Respiratory
Irritation
Authorized
Personnel Only
Example GHS Inner Container Label (e.g.,
bottle inside a shipping box)
ToxiFlam (Contains: XYZ)
Danger! Toxic If Swallowed, Flammable Liquid and Vapor
Do not eat, drink or use tobacco when using this product. Wash hands thoroughly after handling. Keep container tightly closed. Keep away from heat/sparks/open flame. - No
smoking. Wear protective gloves and eye/face protection. Ground container and receiving equipment. Use explosion-proof electrical equipment. Take precautionary
measures against static discharge. Use only non-sparking tools. Store in cool/well-ventilated place.
IF SWALLOWED: Immediately call a POISON CONTROL CENTER or doctor/physician.
Rinse mouth.
In case of fire, use water fog, dry chemical, CO2, or "alcohol" foam.
See Material Safety Data Sheet for further details regarding safe use of this product.
MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999
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Example GHS Outer Container Label (55
gallon/200 liter drum)
Flammable liquids, toxic, n.o.s.
Danger! Toxic If Swallowed Flammable Liquid and Vapor (contains XYZ)
UN 1992 Do not eat, drink or use tobacco when using this product. Wash hands thoroughly after handling. Keep container tightly closed. Keep away from
heat/sparks/open flame. - No smoking. Wear protective gloves and eye/face protection. Ground container and receiving equipment. Use explosion-proof electrical equipment.
Take precautionary measures against static discharge. Use only non-sparking tools. Store in cool/well-ventilated place
IF SWALLOWED: Immediately call a POISON CONTROL CENTER or doctor/physician. Rinse mouth.
In case of fire, use water fog, dry chemical, CO2, or "alcohol" foam.
See Material Safety Data Sheet for further details regarding safe use of this product.
MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999
Training Requirements
Training Requirements
The new standard does not impose
employee training requirements; however,
OSHA believes that additional training will
be necessary to ensure that employees
understand the new elements, particularly
on the new pictograms.
Therefore, modified training requirements
have been included in the final rule in order
to address the new label elements and SDS
format required under this revised standard.
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Training Requirements
Employers shall provide employees with
effective information and training on
hazardous chemicals in their work area at
the time of their initial assignment, and
whenever a new chemical hazard the
employees have not previously been trained
about is introduced into their work area.
Information and training may be designed
to cover categories of hazards (e.g.,
flammability, carcinogenicity) or specific
chemicals.
Training Requirements
OSHA estimates that employee training will
take up to:
One Hour per production employee in
most industries
Thirty minutes in occupations exposed to
a few hazardous chemicals and types of
hazards
Ten minutes per employee in some
occupations where GHS-type pictograms
are already in use
Important Dates to Remember
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Important Dates to Remember
December 31, 2013. Employers must train
employees on the new label elements contained in
the standard and the new format for Safety Data
Sheets.
June 1, 2015. Chemical manufacturers, importers,
distributors and employers must comply with all
modified provisions of the revised Hazard
Communication Standard except that distributors
of chemicals covered by the standard are allowed
to ship products, labeled by manufacturers under
the old system, until December 1, 2015.
Important Dates to Remember
June 1, 2016. Employers are required to
update alternative workplace labeling and
their written Hazard Communication
Program to bring them into full compliance
with the revised standard and to provide
additional training for newly identified
physical or health hazards.
Other OSHA Regulations Affected
Laboratory Standard
Need to update the definitions
Hazardous Waste Operations and Emergency
Response
Need to update definitions
Need to train on the new labels, physical and health hazards
Spray finishing
New flammable liquid requierments
Welding, Cutting and Brazing
Changes to the Substance Specific Standards (lableling)
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Other U.S. Agencies Effected
The Department of Transportation (DOT),
Environmental Protection Agency (EPA), and the
Consumer Product Safety Commission (CPSC)
were actively involved in developing the GHS.
DOT has already modified their requirements for
classification and labeling to make it consistent
with international UN transport requirements and
the GHS.
Questions??
Thank you
Rick Foote
Consulting Services Manager, Industrial
617-686-6184