globally harmonized system (ghs): compliance strategies · united nations’ (un) globally...
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Globally Harmonized System (GHS): Compliance Strategies
Jim Larson, CPEA, CHMM EORM Principal Consultant [email protected] 408.790.9241
About EORM
History – Founded in 1990 by Environmental, Health and Safety (EHS)
managers to offer comprehensive EHS management and technical consulting services to the high tech industry
– In late 90s, successfully diversified our client base into multiple regional and vertical markets across the US and beyond
Today – 140 employees supporting 350 customers from 6 regional offices
in US; HQ in San Jose, CA – Multidisciplinary EHS and Sustainability consulting team – Well-established strategic partnering arrangements allowing for
cost effective and highly responsive international support – ISO 14001 and OHSAS 18001 Certified
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What EORM Does
At EORM we make a positive impact on the world every day. We do this by enabling companies to be socially and globally responsible, protecting employees, preserving the environment, and building long-term sustainable solutions.
Find out more on our website at www.eorm.com
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EORM Services
EHS Auditing EHS Compliance
– Environmental Compliance – Ergonomics – Industrial Hygiene – Process Safety – Safety Engineering
Asbestos, Lead, Mold & Remediation (Phase I-III)
Construction EHS Services
EHS Outsourcing Management Consulting
– EHS Strategic Planning – Management Systems
» ISO 14K, OHSAS 18K, ISO 28K, ISO 50001
– Business Continuity Planning
Sustainability Services
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Introductions
Jim Larson – Principal Consultant – Certified Professional Environmental Auditor – Certified Hazardous Materials Manager – Experience in industry & consulting
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Agenda
What is the GHS Vision / Legislation for GHS OSHA Timeline Transitioning Your Organization What Has to be Updated? Hazard Types, Classes, Categories Audience Discussion Summary w/ Helpful Links
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What is the GHS?
United Nations’ (UN) Globally Harmonized System (GHS) of Classification and Labeling of Chemicals
Worldwide initiative to promote a standardized classification and labeling of chemicals. Adopted in 1992
Activities, preparation, and implementation varies by country
GHS is not a regulation or standard
OSHA adopted GHS elements into the HazCom Standard in May 2012. “Right to Understand”
http://www.osha.gov/dsg/hazcom/hazcom-faq.html
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GHS Benefits
Increase quality / consistency for communicating hazards
Data driven to enhance protection of human health & environment
Improve protection of workers / public from chemical hazards
Recognized framework for countries without existing systems
Facilitate international trade
Reduce fatalities
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Current Labeling System (Caffeine Example)
From Merck w/ modification http://www.emdmillipore.com
New Zealand: LD50 oral: 261 mg/kg
Labeling Under GHS (Caffeine Example)
From Merck w/ modification http://www.emdmillipore.com
Danger – Acute toxicity, oral
Where Should I Begin?
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Where Should I Begin?
Stay informed
Complete a gap analysis
Evaluate your chemical inventory
Acquire & maintain SDS
Re-label chemical containers
Evaluate alternative workplace labeling
Train affected employees
Update the written program
Communicate any new hazards
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Questions to Consider
Are you familiar with the standard(s)?
Where are your facilities located?
When was your written plan reviewed?
What are your methods of delivering training?
What role will your internal/external vendors play?
What recent business changes have/will occur?
What resources do you have?
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Stay Informed
Learn how GHS elements will affect your organization
Understand when countries implement GHS elements (varies by country) – United Nations Economic Commissions for Europe (UNECE)
www.unece.org/trans/danger/publi/ghs/implementation_e.html#c25877
– Federal / State Regulatory Updates – Regulatory Conferences – Association Meetings
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Federal OSHA Timeline
Key implementation dates: http://www.osha.gov/dsg/hazcom/effectivedates.html
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Dec 1, 2013 • Employers must
train employees on new label elements & safety data sheet (SDS) format
June 1, 2015 • Chemical
manufacturers, importers, and employers must comply with all modified provisions of the final rule
• Except:
Dec 1, 2015 • Distributors shall
not ship containers labeled by the chemical manufacturer or importer unless it has a GHS label
June 1, 2016 • Employers to
update alternative workplace labeling and hazard communication programs
• Provide additional employee training for new hazards
Complete A Gap Analysis
Transitioning your organization will take time – Having a prioritized strategy is helpful
EORM recommendation: “Full Phased Approach” vs. waiting for key deadlines
If actively implementing, how often should you re-assess?
Evaluate current methods/activities and how your organization defines select terminology
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Chemical Inventory & SDSs
How accurate and when was your last chemical inventory?
How do you acquire/manage SDS?
Do you need to re-author SDS?
30-year MSDS (SDS) requirement – Various regulations require
employers to maintain MSDS’/SDS’ after an exposure or incident involving exposure
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http://www.airliquide.com/
Classification of Hazards
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• Physical, Health, & Environmental
Hazard Types
• Refers to the nature of the physical, health or environmental hazard, such as flammable solid, carcinogen, acute toxicity, etc.
Hazard Classes
• Each hazard class contains five (5) hazard categories
Hazard Categories
Hazard Types & Classes
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Hazard Category Designation
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Less Hazardous
Hazard category may or may not have a pictogram indicating nature of the hazard
NFPA hazard numerical designation concern
Evaluate alternative workplace labeling
Label Requirements
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Name, Address & Phone # of Manufacturer, Importer, or Responsible Party
Product Identifier: chemical identity of the hazardous substance. Needs to match SDS
Hazard Statement(s)
Precautionary Statement(s) There are four types: “prevention”, “response”, “storage”, and “disposal”
Pictogram: while most pictograms will consist of the symbol in a red diamond, some counties allow use a black border in certain instances
Signal Word (if indicated): Either Danger (more severe) or Warning (less severe)
Train Affected Employees
Evaluate training and method of delivery Training must be completed by
December 1, 2013 (Fed-OSHA) Review should include the new:
Signal words and labeling Hazard pictograms SDS 16-section format
Note: Dual program requirements (until regulation is fully phased)
OSHA’s Model Training Program: http://www.osha.gov/dsg/hazcom/MTP101703.html
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Finally: Update Your Program
Integrate new GHS requirements into the written program
HazCom Program elements: http://www.osha.gov/dsg/hazcom/solutions.html
Communicate any ‘new hazards’ identified
Due June 1, 2016
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How Often Should I be Assessing our Progress?
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Summary of Federal Timeline
Key implementation dates: http://www.osha.gov/dsg/hazcom/effectivedates.html
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Dec 1, 2013 • Employers must
train employees on new label elements & safety data sheet (SDS) format
June 1, 2015 • Chemical
manufacturers, importers, and employers must comply with all modified provisions of the final rule
• Except:
Dec 1, 2015 • Distributors shall
not ship containers labeled by the chemical manufacturer or importer unless it has a GHS label
June 1, 2016 • Employers to
update alternative workplace labeling and hazard communication programs
• Provide additional employee training for new hazards
Useful Links
OSHA GHS Fact Sheets – www.osha.gov/dsg/hazcom/HCSFactsheet.html
OSHA GHS QuickCards – www.osha.gov/dsg/hazcom/ghsquickcards.html
Official UN GHS Website (Country by Country comparison) – www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html
Comparing GHS to Federal HazCom by Line Item – www.osha.gov/dsg/hazcom/ghoshacomparison.html#footnote1
Classification, Labeling & Packaging (CLP) Regulations – echa.europa.eu/legislation/classification_legislation_en.asp
Shipping by Hazard Category, Signal Word, and Hazard Statements – www.sitehawk.com/ghs_hazard_physical_content.html
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Audience Discussion
What BMPs Have You Learned?
What advice do you have?
What challenges have you encountered?
How has the new requirements affected your organization?
How are you managing SDS in other countries?
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