Today we’re going to talk about the revisions to OSHA’s Hazard Communication Standard, or HazCom. OSHA has amended the Hazard Communication Standard (29 CFR 1910.1200) to align its requirements with the Globally Harmonized System for the Classification and Labeling of Chemicals, or GHS. We’ll give you an overview of GHS and talk about how it has changed HazCom so that you can understand the effect of the changes on your workplace.

Session Objectives

The main objective of this session is to describe the purpose of GHS revisions to OSHA’s Hazard Communication Standard. By the time the session is over, you should be able to:

• Understand the GHS revisions to HazCom and how they affect our workplace,
• Recognize the revised chemical labels and safety data sheets, or SDSs, and
• Train employees to read and interpret GHS-compliant labels and SDSs.

How Much Do You Already Know?

Before we begin the session, let’s take a few minutes to see how much you already know about GHS. Decide whether each statement on the screen is TRUE or FALSE.

• Under GHS, the United Nations now regulates workplace hazardous chemicals. – This is false.
• GHS-compliant SDSs are less informative than material safety data sheets, or MSDSs. – This is false.
• GHS will create a safer work environment for us. – This is true.
• Chemical labels are no longer required in the workplace. – This is false.

How did you do? Did you get all the answers right?

If not, don’t worry. You’ll learn all about these issues and a lot more during the session.

What is GHS?

• GHS stands for the Globally Harmonized System of Classification and Labeling of Chemicals.
• It was developed by the United Nations to provide a universal approach to classifying and labeling hazardous chemicals. Before GHS, different governments had different requirements for hazard communication information. GHS aims to streamline regulations by providing a central system for regulating bodies to employ.
• GHS is being implemented by governments all over the world, including here in the United States.

The Goal of GHS Amendments To HazCom

The basic goal of hazard communication is to ensure that employers and employees are provided with adequate practical, reliable, and comprehensible information on chemical hazards in the workplace. Implementation of GHS is expected to:

• Create a safer work environment for you and your employees.
• Reduce workplace accidents and illness caused by chemical exposure.
• Provide consistent and simplified communications about substances and safe work practices.
• Create greater awareness of hazards, resulting in safer use of substances in the workplace.
• Make HazCom compliance easier and less costly.
• And finally, enhance the protection of workers from chemical exposure.

How Does GHS Change HazCom?

The GHS amendments are designed to make compliance with HazCom easier to achieve in the long run. They will bring a common and coherent approach to classifying chemicals and communicating hazard information on labels. The amendments affect the following sections of the Hazard Communication Standard:

• GHS hazard classification replaces the former hazard determination requirements that apply to chemical manufacturers and importers.
• GHS-compliant chemical labels and designs.
• SDSs replace MSDSs.
• Employee training must cover the new GHS-compliant labels and SDSs.
• The written hazard communication plan must be updated to reflect the new labels and SDSs.

Complying with GHS HazCom Amendments

OSHA is phasing in GHS changes to the HazCom rule as follows:

• By December 1, 2013, all employers that use, handle, and/or store chemicals must train employees on how to read and interpret the new chemical labels and SDSs.
• By June 1, 2015, chemical manufacturers and importers must comply with all requirements of the revised HazCom standard.
• By December 1, 2015, distributors must ship all chemical containers with a GHS-compliant label.
• By June 1, 2016, all employers that use, handle, and/or store chemicals must update their alternative workplace labeling and hazard communication program as necessary and provide additional employee training for newly identified hazards.

Hazard Classification

• The quality of the employer’s hazard communication program depends on how adequate and accurate the process is for the evaluation and classification of hazards. Employers and their employees must understand which chemicals and chemical mixtures in the workplace are hazardous.
• Under the GHS amendments, chemical manufacturers and importers have to follow new criteria to evaluate each chemical they produce or import in order to classify the chemicals and chemical mixtures according to their physical and health hazards. Chemicals will be classified on the basis of:

– The type of hazard;

– The degree; and

– The severity of the hazard.

• Hazard classes may include several categories within a hazard class. The categories compare the severity of a hazard within a class and provide additional information that can be used in response to a hazard, thus increasing workplace and worker safety.
• The new hazard classes and related categories will be displayed on chemical labels and SDSs. The categories on labels will be displayed as a signal word and hazard statement.

Exercise

Now let’s try a TRUE or FALSE exercise to test your knowledge of the information presented in the previous slides.

• OSHA has incorporated the UN’s GHS into its Hazard Communication Standard. – This is true.
• GHS will make HazCom compliance more difficult to achieve. – This is false.
• The United States is the only country implementing GHS. – This is false.
• Chemical classification requirements are different under the revised HazCom Standard. – This is true.
• Hazard classification is no longer based on physical and health hazards. – This is false.

How did you do? Were you able to identify the correct answers to each statement?

Review Questions

Now it’s time to ask yourself if you understand the information that has been presented so far. For example, do you understand what we’ve said about:

• Why this course is important?
• Why GHS was created?
• OSHA’s adoption of GHS into the HazCom Standard?
• How GHS changes HazCom?
• The phased compliance dates of the GHS amendments?
• Hazard classification?

All this information will help you understand GHS and explain it to your employees. Let’s continue now and talk about GHS chemical labels and safety data sheets.

Hazards and Protective Measures

When working with chemicals, the most important thing you can do is protect yourself and the people working for you.

• Understand what a chemical is before anyone uses it … know the physical and health hazards.
• The container labels will provide brief information on any hazards and the necessary protective measures.
• For detailed information, check the safety data sheet for the substance you are using.

Other Chemical Hazards

In addition to the physical and health hazards we’ve discussed, there are other hazards that you may encounter that are dangerous to life and property in the workplace:

• Asphyxiation, or asphyxia—is a condition where there is not enough oxygen in the air to breathe normally, leading to suffocation. A simple asphyxiant is a chemical that displaces oxygen in the air and causes rapid suffocation. Pure nitrogen is an example of an asphyxiant.
• Pyrophoric gas—is a chemical that catches fire spontaneously if exposed to air.
• Combustible dust—is a chemical in dust form that may form explosive concentrations of dust in the air. In some cases, a chemical is shipped in a form that is not yet dust, but under normal conditions of use or processing, it will form a combustible dust.
• Hazards Not Otherwise Classified—represents a chemical that may have hazardous physical or health effects, but the specific effects have not been identified under the hazard classification process outlined in the hazard communication rule.

Hazard Detection and Monitoring

There are several ways to detect chemical hazards in your work area.

• Visual appearance—for example, you can see chemical reactions such as smoke, froth, mists, fumes, or fire coming from a chemical or its container.
• Continuous monitoring device—for some chemicals or other toxic substances, there may be monitoring devices in work areas to detect concentrations in the air that exceed safe limits. Your supervisor will provide you with information about such devices, if any.
• Odor—sometimes an unusual odor will be your first indication of exposure to a chemical. Report any unusual odors to your supervisor.

What’s on a GHS-Compliant Label?

GHS-compliant container labels will include information about each hazard class and category of chemical. You will find the following information on GHS-compliant chemical labels:

• Product identifier,
• Supplier identification,
• Signal word,
• Pictogram,
• Hazard statement,
• Precautionary statement, and
• Supplemental information.

Let’s take a look at each element.

What’s on a GHS-Complaint Label? (cont.)

The chemical label must contain both a product identifier for the chemical and supplier identification information.

• The product identifier is:

– The name or number that allows you to identify the chemical in the container.

– The identifier must allow for cross references between the label, the written hazard communication plan, and the safety data sheet.

• Supplier identification must include:

– The name,

– Address, and

– Telephone number for the chemical manufacturer, importer, or other responsible party.

• The chemical label will include one of two signal words that tell you the relative severity of the hazard presented. It alerts you to a potential hazard. For example:

– “Danger” is the more serious of the signal words and indicates a higher level of hazard.

– “Warning” is less serious than “danger” and indicates a lower hazard level.

What’s on a GHS Compliant Label? (cont.)

• Hazard statements assigned to a hazard class or category appear on the label. They describe the nature of the hazard and, where appropriate, the degree of the hazard. These statements in combination with the signal word can be cross-referenced with the hazard category in Section 2 of the SDS. The statement can include information on the hazards of exposure, such as being fatal or toxic, or causing organ damage, and routes of exposure. For example, a hazard statement could say:

– Highly flammable liquid and vapor.

– May cause liver and kidney damage.

• Precautionary statements describe recommended measures that should be taken to minimize or prevent harmful effects from exposure to a chemical or improper storage or handling. Four types of precautionary statements can appear on a chemical label. They are:

– Prevention. For example, “Wash thoroughly after handling.”

– Response. For example, “If swallowed, immediately call a poison center.”

– Storage. For example, “Store locked up.”

– Disposal. For example, “Dispose of in accordance with local, regional, national, and international regulations as specified.”

What’s on a GHS-Complaint Label? (cont.)

• Pictograms include a symbol and other graphic elements that convey specific information about the hazards of a chemical. They appear on a white background within a diamond with a red border and are placed on the label on the basis of a chemical’s hazard classification.
• Eight standardized hazard symbols are displayed in pictograms, each of which conveys the specific hazard of the chemical.
• Supplemental information includes any additional information provided on the chemical label that is not required or specified by GHS.

Container Labels

• Generally, all containers of hazardous chemicals supplied to the workplace must be labeled. The labels on containers delivered to your facility must either be kept intact or, if removed or damaged, be immediately marked with the required information. This includes the product identifier and a combination of words, pictures, or symbols that provide general information about the chemical hazards and specific information regarding the potential physical and health hazards.
• Labels are required on all portable and secondary containers if not for immediate use. The label must include the chemical identification and the hazards it presents.
• Labels are not required on:

– Pipes or piping systems, or

– Portable containers where the hazardous chemical is transferred from a labeled container for immediate use by the employee doing the transfer.

Safety Data Sheets

• The SDS replaces the MSDS we’re all familiar with.
• The GHS-compliant SDS is composed of 16 sections. The information it presents may be more complete than what you’re used to in the old MSDS, and it’s better organized.
• If you’ve used the 16-section ANSI MSDS format, you’ll be familiar with the structure and content of the SDS.

Sections 1-4

• Section 1 of the SDS contains the product identifier and other means of identification, recommended uses and restrictions, supplier information, and a 24/7 emergency number.
• Section 2 contains the hazard classification and hazard category, the signal word, hazard and precautionary statements, hazard symbol, other hazards not otherwise classified, and statements regarding mixtures consisting of ingredients of unknown toxicity.
• Section 3 contains information about chemical composition and ingredients, including chemical name, common name and synonyms, CAS number and other unique identifier, and impurities and stabilizing additives that are classified and that contribute to the classification of the substance.
• Section 4 contains a description of necessary first aid, symptoms and health effects (acute and delayed), and the need for immediate medical attention and special treatment (if required).

Section 5-8

• Section 5 contains information about suitable and unsuitable extinguishing substances, specific hazards of the chemical, special PPE, and precautions for firefighters.
• Section 6 contains information about personal precautions and PPE, emergency precautions, environmental procedures, and containment and cleanup methods and materials.
• Section 7 contains information about precautions for safe handling and conditions for safe storage.
• Section 8 contains information about control parameters (such as exposure limit values), engineering controls, and individual protection measures and PPE.

SDS Section 9-11

• Section 9 contains information about the substance’s physical and chemical properties, for example, appearance, odor, melting and freezing points, flash point, and flammability.
• Section 10 contains information about the substance’s stability or reactivity, possible hazardous reactions, conditions to avoid, incompatible materials, and hazardous decomposition products.
• Section 11 contains information about likely routes of exposure, symptoms, immediate and delayed health effects, numerical measures of toxicity, and whether the chemical is listed in the National Toxicology Program Report on Carcinogens, the International Agency for Research on Cancer Monographs, or by OSHA.

SDS Sections 12-14

• Section 12 identifies the substance’s ecotoxicity, persistence and degradability, bioaccumulative potential, mobility in soil, and other adverse environmental effects.
• Section 13 provides information on waste residues and safe handling and disposal of substances and contaminated packaging.
• Section 14 gives information on the safe transportation of the chemical.

SDS Sections 12-14

• Section 15 contains safety, health, and environmental regulatory information.
• Section 16 provides other relevant information.

Section headings 12–15 are required on all SDSs, but OSHA does not require any specific information to be included in the sections.

Employee Training

• The GHS amendments to HazCom preserve the employee information and training requirements under the pre-GHS standard. However, there are additional employee training requirements under the GHS amendments.
• By December 1, 2013, employers must train employees to:

– Read and interpret GHS-compliant labels.

– Read and interpret SDSs.

– Where applicable, add training about the hazards of simple asphyxiation, combustible dust, pyrophoric gas, and hazards not otherwise classified.

• Workplaces may begin to receive chemical labels and SDSs that are consistent with GHS well before the compliance deadlines. Therefore, make sure that when employees begin to see the new GHS-compliant labels and SDSs in their workplaces, they will be familiar with them, understand how to use them, and know how to access the information effectively.

Exercise

Now it’s time for a quick review of the information provided. See if you can identify which of the things on the blackboard appear on a GHS chemical label.

• Regulatory Information – No
• Supplier Identification – Yes
• Pictogram – Yes
• First-Aid Information – Yes
• Product Identifier – Yes
• Signal Word – Yes

All but regulatory information appear on a chemical label. Did you get them all right?

Review

Let’s review briefly now to make sure you understand the information presented in the previous slides. Do you understand what we’ve said about:

• Hazard Communication using GHS?
• GHS Chemical Labels?
• The new safety data sheet?, and
• Employee training?

It’s important that you understand this information so that you will be able to help make us compliant with the GHS-amended Hazard Communication Standard and keep our workplace and workers safe.

Let’s continue now to the last slide and look at some key points to remember about this training session.

Key Points to Remember

Here are the main points to remember from this training session on understanding the Globally Harmonized System.

• OSHA used GHS to modify the Hazard Communication Standard.
• GHS provides standardized safety and health information, regardless of national boundaries.
• Implementing GHS will make workplaces and workers safer.
• GHS will make American businesses more competitive.
• The amendments to HazCom mean new chemical labels and safety data sheets.

This concludes the Hazard Communication and GHS training program.