the globally harmonized system is here! are you ready?
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The Globally Harmonized System is Here! Are You Ready?. Larry K. Seabolt Jr., CHMM Senior Engineer. Hazard Communications Standard / Globally Harmonized System. Title of presentation references Globally Harmonized System - PowerPoint PPT PresentationTRANSCRIPT
PowerPoint PresentationLarry K. Seabolt Jr., CHMM
Senior Engineer
Title of presentation references Globally Harmonized System
In actual terms of what has transpired – OSHA has modified the Hazard Communications Standard (HCS) to follow the Globally Harmonized System (GHS)
We in the US will still have a Hazard Communications Standard (HCS) we must follow
The HCS has been revised to follow the EU’s GHS Revision 3
HCS under ghs frame work
Outline:
What changes are required?
What does it cover?
The Globally Harmonized System (GHS) is a revision to the United States current Hazard Communications Standard (HazCom)
It is the system for labeling and classifying hazardous chemicals that we use/store/manufacture/distribute
How we will recognize the hazards of a particular product
How chemicals are classified / grouped
HCS under ghs frame work
What changes are covered?
Hazard Classification
Several chemical classifications under the 1994 HCS were deleted in the HCS 2012
Combustible liquid, Compressed gas, Explosive, Flammable, Flashpoint, Organic peroxide, Oxidizer, Pyrophoric, Unstable (reactive), and Water-reactive
While the hazards are still evaluated and considered, the 1994 definition and classifications do not exist in the new system
The term “physical and heath hazard” has been replaced with the term “chemical hazard”.
HCS under ghs frame work
What changes are covered?
Labels
All labels are required to contain the pictogram, harmonized signal word and hazard statement
Safety Data Sheets (SDS)
The word “Material” has been dropped and the correct term is now Safety Data Sheet (SDS)
All SDS will be in a 16 section format
HCS under ghs frame work
Who is affected?
Anyone one who deals with hazardous materials, even down to the consumer level
Employees of your facility who may not handle the hazardous materials but have a right-to-know
OSHA estimates that 32 million workers are exposed to 650,000 hazardous chemicals in more than 3 million workplaces
HCS under ghs frame work
What is the time frame?
Final rule adopted March 26, 2012
Became final May 25, 2012
Training
Employers have until December 1, 2013 to train employees on new label elements and SDS sheet format (employers are responsible for this)
HCS under ghs frame work
What is the time frame?
Implementation –
June 1, 2015 – Compliance with all modified provisions of the final rule (this applies to chemical manufacturers, importers, distributors and employers)
NOTE: This is also the EU implementation date for classification of all mixtures
Distributors may still ship products under the old label system until December 1, 2015
December 1, 2015 – All containers must be labeled with a GHS formatted label in order to be shipped
NOTE: DOT markings are NOT changing as part of GHS
HCS under ghs frame work
What is the time frame?
Implementation –
June 1, 2016 – All alternative workplace labeling and hazard communication programs must be updated and functional by this date (employers)
HCS under ghs frame work
What changes are required?
Before December 1, 2013 –
Training needs to be updated to all employees on the new system
It is recommended that charts/posters be used initially to help familiarize employees with the new symbols / warning key words / labels
Depending on what chemicals are being used in your facility, these symbols and words may already be required and are on labels/packaging/SDS now
EU began this process in 1994
HCS under ghs frame work
Hazard Classifications - Changes
There are specific criteria for classifying health and physical hazards
Mixtures must also be classified
Hazards must be classified by level of severity (from 1 – 4 with 1 being the most severe) – this is different from NFPA labeling structure
HCS under ghs frame work
Hazard Classifications
Only intrinsic hazardous properties of chemicals are considered in the HCS 2012
Testing is not required to classify chemicals, however, manufacturers and importers are required to properly identify the hazards
Information is listed in Appendix A (health hazard) and Appendix B (physical hazard) of the standard (1910.1200 App A & App B)
Hcs under ghs framework
Examples of changes
Flammable liquids are defined differently and the term “combustible liquid” is no longer used
Classifications:
HCS 1994 stated:
"Liquid, flammable" means any liquid having a flashpoint below 100 deg. F (37.8 deg. C), except any mixture having components with flashpoints of 100 deg. F (37.8 deg. C) or higher, the total of which make up 99 percent or more of the total volume of the mixture.
"Combustible liquid" means any liquid having a flashpoint at or above 100 deg. F (37.8 deg. C), but below 200 deg. F (93.3 deg. C), except any mixture having components with flashpoints of 200 deg. F (93.3 deg. C), or higher, the total volume of which make up 99 percent or more of the total volume of the mixture.
Category
Criteria
1
Flash point < 23°C (73.4°F) and initial boiling point ≤ 35°C (95°F)
2
Flash point < 23°C (73.4°F) and initial boiling point > 35°C (95°F)
3
Flash point ≥ 23°C (73.4°F) and ≤ 60°C (140°F)
4
Flash point > 60°C (140°F) and ≤ 93°C (199.4°F)
HCS under ghs frame work
Label Changes:
Labels on containers (including certain workplace containers) must have the new label(s)
Some categories cover multiple “hazard classifications” we are familiar with through DOT
If the container requires the DOT warning label (for proper shipping), the HCS 2012 pictogram is not required but may be included
HCS under ghs frame work
Label Revisions:
Product Identifier
Signal Word
Pictogram(s)
Precautionary Statement(s)
Name, address and phone number of the manufacturer, importer or other responsible party
The company can place other information on the label in addition to the above
Hcs under ghs framework
Label Revisions:
Labels on portable containers used for transfers and intended for immediate use by the employee are not required to meet the label requirements
Placards, signs, batch sheets or other identifiers may be used to identify in plant containers in lieu of the required labels.
Hcs under ghs framework
Danger – used for the more severe hazards
Warning – used for less severe hazards
Precautionary Statements
Hcs under ghs framework
Safety Data Sheets (SDS)
Safety Data Sheets are required to be in new 16 section format
Section 1 – Identification
Section 2 – Hazard Identification
The new parts of the HCS2012 (signal words, pictograms, precatuionary)
Section 3 – Composition/Ingredients
Chemical name(s), CAS numbers, common identifiers
For mixtures – exact percentages or concentrations are required except for materials claimed under trade secrets or with batch to batch variations – ranges can by used
Section 4 – First Aid
Section 5 – Fire Fighting
Section 6 – Accident release
What to do when…
Hcs under ghs framework
Safety Data Sheets (SDS)
Safety Data Sheets are required to be in new 16 section format
Section 7 – Handling / Storage
Section 8 – Exposure controls
All of the following are minimum requirements on the SDS
Hcs under ghs framework
Safety Data Sheets (SDS)
Odor;
Flash point;
Evaporation rate;
Vapor pressure;
Vapor density;
Relative density;
Hcs under ghs framework
Safety Data Sheet (SDS)
Safety Data Sheets area required to be in new 16 section format
Section 10 – Stability and reactivity
In three parts – Reactivity, Chemical Stability and other
Section 11 – Toxicological Information
Section 12 – Ecological Information – non mandatory
Affects on environment if released
Section 13 – Disposal considerations – non mandatory
RCRA disposal guidance – regulated by EPA
Section 14 – Transport Information – non mandatory
DOT Transportation guidance
State / local restrictions or regulations
Section 16 – Other information
Preparation date, revisions, etc.
Hcs under ghs framework
Safety Data Sheet (SDS)
The final rule did include:
The disclosure of exposure limits and the carcinogenic affects of materials contained in the product (these were not part of the proposed rule making)
As with former HCS, SDS must be immediately accessible to the employees from their work areas
May be in hard copy or electronic
Must have a backup in case of power failure or emergency
Hcs under ghs framework
At initial work assignment
When new chemical hazards are introduced into the work area
Training must include:
The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified
Hcs under ghs framework
Additional Training Requirements
All affected employees must be updated on the new HCS 2012 portions
The new definitions / hazard classifications of materials
Changes in the definitions
New pictograms
What do the new symbols mean
How will they be used in the work place / identification of materials
Hcs under ghs framework
Additional Training Requirements
All affected employees must be updated on the new HCS 2012 portions
Signal words
What do the words mean and how are they used
December 1, 2013 is the deadline to have all employees trained on the new system
Hcs under ghs framework
Larry Seabolt, Remtech Engineers
Senior Engineer
Title of presentation references Globally Harmonized System
In actual terms of what has transpired – OSHA has modified the Hazard Communications Standard (HCS) to follow the Globally Harmonized System (GHS)
We in the US will still have a Hazard Communications Standard (HCS) we must follow
The HCS has been revised to follow the EU’s GHS Revision 3
HCS under ghs frame work
Outline:
What changes are required?
What does it cover?
The Globally Harmonized System (GHS) is a revision to the United States current Hazard Communications Standard (HazCom)
It is the system for labeling and classifying hazardous chemicals that we use/store/manufacture/distribute
How we will recognize the hazards of a particular product
How chemicals are classified / grouped
HCS under ghs frame work
What changes are covered?
Hazard Classification
Several chemical classifications under the 1994 HCS were deleted in the HCS 2012
Combustible liquid, Compressed gas, Explosive, Flammable, Flashpoint, Organic peroxide, Oxidizer, Pyrophoric, Unstable (reactive), and Water-reactive
While the hazards are still evaluated and considered, the 1994 definition and classifications do not exist in the new system
The term “physical and heath hazard” has been replaced with the term “chemical hazard”.
HCS under ghs frame work
What changes are covered?
Labels
All labels are required to contain the pictogram, harmonized signal word and hazard statement
Safety Data Sheets (SDS)
The word “Material” has been dropped and the correct term is now Safety Data Sheet (SDS)
All SDS will be in a 16 section format
HCS under ghs frame work
Who is affected?
Anyone one who deals with hazardous materials, even down to the consumer level
Employees of your facility who may not handle the hazardous materials but have a right-to-know
OSHA estimates that 32 million workers are exposed to 650,000 hazardous chemicals in more than 3 million workplaces
HCS under ghs frame work
What is the time frame?
Final rule adopted March 26, 2012
Became final May 25, 2012
Training
Employers have until December 1, 2013 to train employees on new label elements and SDS sheet format (employers are responsible for this)
HCS under ghs frame work
What is the time frame?
Implementation –
June 1, 2015 – Compliance with all modified provisions of the final rule (this applies to chemical manufacturers, importers, distributors and employers)
NOTE: This is also the EU implementation date for classification of all mixtures
Distributors may still ship products under the old label system until December 1, 2015
December 1, 2015 – All containers must be labeled with a GHS formatted label in order to be shipped
NOTE: DOT markings are NOT changing as part of GHS
HCS under ghs frame work
What is the time frame?
Implementation –
June 1, 2016 – All alternative workplace labeling and hazard communication programs must be updated and functional by this date (employers)
HCS under ghs frame work
What changes are required?
Before December 1, 2013 –
Training needs to be updated to all employees on the new system
It is recommended that charts/posters be used initially to help familiarize employees with the new symbols / warning key words / labels
Depending on what chemicals are being used in your facility, these symbols and words may already be required and are on labels/packaging/SDS now
EU began this process in 1994
HCS under ghs frame work
Hazard Classifications - Changes
There are specific criteria for classifying health and physical hazards
Mixtures must also be classified
Hazards must be classified by level of severity (from 1 – 4 with 1 being the most severe) – this is different from NFPA labeling structure
HCS under ghs frame work
Hazard Classifications
Only intrinsic hazardous properties of chemicals are considered in the HCS 2012
Testing is not required to classify chemicals, however, manufacturers and importers are required to properly identify the hazards
Information is listed in Appendix A (health hazard) and Appendix B (physical hazard) of the standard (1910.1200 App A & App B)
Hcs under ghs framework
Examples of changes
Flammable liquids are defined differently and the term “combustible liquid” is no longer used
Classifications:
HCS 1994 stated:
"Liquid, flammable" means any liquid having a flashpoint below 100 deg. F (37.8 deg. C), except any mixture having components with flashpoints of 100 deg. F (37.8 deg. C) or higher, the total of which make up 99 percent or more of the total volume of the mixture.
"Combustible liquid" means any liquid having a flashpoint at or above 100 deg. F (37.8 deg. C), but below 200 deg. F (93.3 deg. C), except any mixture having components with flashpoints of 200 deg. F (93.3 deg. C), or higher, the total volume of which make up 99 percent or more of the total volume of the mixture.
Category
Criteria
1
Flash point < 23°C (73.4°F) and initial boiling point ≤ 35°C (95°F)
2
Flash point < 23°C (73.4°F) and initial boiling point > 35°C (95°F)
3
Flash point ≥ 23°C (73.4°F) and ≤ 60°C (140°F)
4
Flash point > 60°C (140°F) and ≤ 93°C (199.4°F)
HCS under ghs frame work
Label Changes:
Labels on containers (including certain workplace containers) must have the new label(s)
Some categories cover multiple “hazard classifications” we are familiar with through DOT
If the container requires the DOT warning label (for proper shipping), the HCS 2012 pictogram is not required but may be included
HCS under ghs frame work
Label Revisions:
Product Identifier
Signal Word
Pictogram(s)
Precautionary Statement(s)
Name, address and phone number of the manufacturer, importer or other responsible party
The company can place other information on the label in addition to the above
Hcs under ghs framework
Label Revisions:
Labels on portable containers used for transfers and intended for immediate use by the employee are not required to meet the label requirements
Placards, signs, batch sheets or other identifiers may be used to identify in plant containers in lieu of the required labels.
Hcs under ghs framework
Danger – used for the more severe hazards
Warning – used for less severe hazards
Precautionary Statements
Hcs under ghs framework
Safety Data Sheets (SDS)
Safety Data Sheets are required to be in new 16 section format
Section 1 – Identification
Section 2 – Hazard Identification
The new parts of the HCS2012 (signal words, pictograms, precatuionary)
Section 3 – Composition/Ingredients
Chemical name(s), CAS numbers, common identifiers
For mixtures – exact percentages or concentrations are required except for materials claimed under trade secrets or with batch to batch variations – ranges can by used
Section 4 – First Aid
Section 5 – Fire Fighting
Section 6 – Accident release
What to do when…
Hcs under ghs framework
Safety Data Sheets (SDS)
Safety Data Sheets are required to be in new 16 section format
Section 7 – Handling / Storage
Section 8 – Exposure controls
All of the following are minimum requirements on the SDS
Hcs under ghs framework
Safety Data Sheets (SDS)
Odor;
Flash point;
Evaporation rate;
Vapor pressure;
Vapor density;
Relative density;
Hcs under ghs framework
Safety Data Sheet (SDS)
Safety Data Sheets area required to be in new 16 section format
Section 10 – Stability and reactivity
In three parts – Reactivity, Chemical Stability and other
Section 11 – Toxicological Information
Section 12 – Ecological Information – non mandatory
Affects on environment if released
Section 13 – Disposal considerations – non mandatory
RCRA disposal guidance – regulated by EPA
Section 14 – Transport Information – non mandatory
DOT Transportation guidance
State / local restrictions or regulations
Section 16 – Other information
Preparation date, revisions, etc.
Hcs under ghs framework
Safety Data Sheet (SDS)
The final rule did include:
The disclosure of exposure limits and the carcinogenic affects of materials contained in the product (these were not part of the proposed rule making)
As with former HCS, SDS must be immediately accessible to the employees from their work areas
May be in hard copy or electronic
Must have a backup in case of power failure or emergency
Hcs under ghs framework
At initial work assignment
When new chemical hazards are introduced into the work area
Training must include:
The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified
Hcs under ghs framework
Additional Training Requirements
All affected employees must be updated on the new HCS 2012 portions
The new definitions / hazard classifications of materials
Changes in the definitions
New pictograms
What do the new symbols mean
How will they be used in the work place / identification of materials
Hcs under ghs framework
Additional Training Requirements
All affected employees must be updated on the new HCS 2012 portions
Signal words
What do the words mean and how are they used
December 1, 2013 is the deadline to have all employees trained on the new system
Hcs under ghs framework
Larry Seabolt, Remtech Engineers