osha’s revised hazard communication standard:
DESCRIPTION
OSHA’s Revised Hazard Communication Standard: What You Need to Do Now to Comply with HazCom 2012!. Chuck Haling. Vice President of Sales, MSDSonline. Goals for this Presentation. Avoid This…. Brief Review of OSHA’s HCS Discuss OSHA’s Alignment with the GHS - PowerPoint PPT PresentationTRANSCRIPT
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
1
OSHA’s Revised Hazard Communication Standard:What You Need to Do Now to Comply with HazCom 2012!
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
2
Chuck HalingVice President of Sales, MSDSonline
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
3
Goals for this Presentation
Avoid This….
Brief Review of OSHA’s HCS
Discuss OSHA’s Alignment with the GHS
Understand reasons for adoption
Learn how to comply
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
4
What is HCS?
An OSHA Regulation
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
5
`
A.K.A…
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
Hazard Communication
1910.1200
The Reg
HazCom Standard
HazCom
The HazCom Reg
29 CFR 1910.1200
Right-to-Know
RTK
HCS
6
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
7
What is HCS?
Hazard Communication Standard
An OSHA Regulation – protect workers from hazardous chemicals
Adopted in 1983
Covers 43+ Million U.S. Workers
5 Million Workplaces
Over 880,000 Chemicals
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
8
Purpose of HCS
“…to ensure hazards of all chemicals produced or imported are evaluated and
details regarding their hazards are transmitted to employers and employees”
“Ensure requirements are consistent nationwide”
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
9
HCS Main Requirements
Written Plan
Chemical Inventory
Labels & Warnings
Training
MSDS Documents
11
22
33
44
55
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
10
Chemicals Covered – Old HCS
Physical Hazards Combustible Liquids Compressed Gases Explosives Flammables Organic Peroxides Oxidizers Pyrophorics Unstable (Reactive) Materials Water-Reactives
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
11
Chemicals Covered – Old HCS
Health HazardsChemicals that may produce acute or chronic health effects in exposed employees.
Nephrotoxins
Neurotoxins
Agents which act on the hematopoietic system
Agents which damage the lungs, skin, eyes or mucous membranes
Carcinogens
Toxic agents
Reproductive toxins
Irritants
Corrosives
Sensitizers
Hepatotoxins
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
12
Who has Responsibilities
Chemical Manufacturers Evaluate and now also classify hazards of chemicals Provide labels & MSDSs to employers to which they ship
chemicals
Importers & Distributors Provide labels & MSDSs to employers to which they ship
chemicals
Employers Who “Use” ChemicalsAre responsible for the following as part of a compliant HazCom program:
1. Written Hazard Communication Plan / Program
2. Written Chemical Inventory
3. Ensuring proper use of Labels and Warnings
4. Maintaining MSDSs and providing Right-to-Know access to employees
5. Providing Employee Training
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
13
The Problem
Regulations vary widely internationally E.g., U.S. has HazCom Standard, Canada has WHMIS,
Europe has CLP
Different agencies within the same country may have jurisdiction over hazardous chemical use and safety E.g., in the U.S.: EPA, DOT, OSHA, Consumer Product Safety
Commission
Multiple labels & MSDSs required for same product to satisfy different country & agency requirements Resulting in confusion for end-users Creating trade issues/hassles multinational companies Costly & time consuming to manage
When it comes to Hazard Communication…
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
14
Enter GHS
GHS = Globally Harmonized System of Classification and Labelling of Chemicals 1st edition approved in 2002 and published by UN in 2003
Result of international mandate (Chapter 19 of Agenda 21) from 1992 Rio Earth Summit (i.e.,UNCED) Deemed to be single most important driving force behind the creation of GHS Aimed to be completed GHS by 2000 A coordinating group chaired by OSHA was established to manage the work
Common & coherent global approach To Classifying and Defining
& Communicating Hazards
Provides Consistency/Harmonization to Labels and Safety Data Sheets
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
15
GHS At-A-Glance
GHS is Not… A Regulation, Standard or Mandate
GHS is… An Approach. It contains criteria, provisions, and
explanatory text for harmonizing hazard communication
Adaptable by Country (and Agency) Referred to as the “Building Block Approach”
Select parts of system that apply to existing regulations
Implementation consistent with requirements in place, or can use to create new requirements
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
16
Why is GHS Needed?
Better Trade
Compliance with multiple regulations is costly
and time-consuming
Regulatory burdens make it difficult for companies to compete internationally
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
17
OSHA Alignment with GHS
Revise HCS to Align with GHS Maintain HCS framework Enhance protection Based on GHS Rev 3 (2009)
Major Changes Chemical Classification Safety Data Sheets (SDSs) Labels
Compliance Enforcement – Phased In Employees Trained on How to Read SDS/Label by Dec. 1, 2013 Manufacturers and Distributors Complete Reclassification and Produce
Updated SDSs and Labels by June 1, 2015 Distributors may ship inventory with old SDS/Labels until Dec. 1, 2015
Full Employer Compliance Expected by June 1, 2016 Transitional Period can comply with old or new HCS/HazCom 2012
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
18
Employee Training
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
19
Principle’s of OSHA’s Alignment
HCS requirements will not be reduced
Modifications made to support GHS
Not a total rewrite of the regulation
Bulk of tech requirements in Appendices Versus regulatory text Largely apply to chemical
producers vs. users
OSHA estimates net savings for employers to be over $500 million/year
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
20
HCS / HazCom 2012 Appendicies
Appendix A: Health Hazard Criteria
Appendix B: Physical Hazard Criteria
Appendix C: Allocation of Label Elements
Appendix D: Safety Data Sheets
Appendix E: Definition of "Trade Secret”
Appendix F: Guidance for Hazard Classification Regarding Carcinogenicity
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
21
Two Most Prevalent Changes
Hazard Classification Criteria Health & Environmental Hazards Physical Hazards Mixtures
Hazard ‘Communication’ Labels Safety Data Sheets Training
OSHA is referring to revisedstandard as “HazCom 2012”
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
22
Two Most Prevalent Changes
“"Classification" means to identify the relevant data regarding the hazards of a chemical; review those data to ascertain the hazards associated with the chemical; and decide whether the chemical will be classified as hazardous according to the definition of hazardous chemical in this section.”
OSHA added the definition of Classification to the revised standard:
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
23
Two Most Prevalent Changes
2nd Key Component of the New Definition:
“In addition, classification for health and physical hazards includes the determination of the degree of hazard, where appropriate, by comparing the data with the criteria for health and physical hazards.”
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
24
UN’s GHS Hazard Classifications
Health & Environmental Acute Toxicity Aspiration Toxicity Skin Corrosion/Irritation Serious Eye Damage/Eye
Irritation Respiratory or Skin
Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Target Organ Systemic
Toxicity – Single and Repeated Dose
Hazardous to the Aquatic Environment/Aquatic Toxicity
Hazardous to the Ozone Layer
Physical Explosives Flammable – Gases,
Aerosols Liquids, Solids Oxidizers– liquids, solids,
gases Self-Reactive Substances Self-Heating Substances Pyrophoric – liquids, solids Organic Peroxides Corrosive to Metals Gases Under Pressure Water-Activated Flammable
Gases
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
25
HazCom 1994 vs HazCom 2012
HCS/HazCom 1994Gases Under Pressure
Carcinogenicity
GHS Alignment/ HazCom 2012
Compressed Gases
Refrigerated Gases
Liquefied Gases
Dissolved Gases
Carcinogenicity Category 1
1A = Known 1B = Probable
Category 2 Suspected
Note the numbering scheme: Lower the #, the more severe the hazard
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
26
UN’s GHS Hazard Classifications
Health & Environmental Acute Toxicity Aspiration Toxicity Skin Corrosion/Irritation Serious Eye Damage/Eye
Irritation Respiratory or Skin
Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Target Organ Systemic
Toxicity – Single and Repeated Dose
Hazardous to the Aquatic Environment/Aquatic Toxicity
Hazardous to the Ozone Layer
Physical Explosives Flammable – Gases,
Aerosols Liquids, Solids Oxidizers– liquids, solids,
gases Self-Reactive Substances Self-Heating Substances Pyrophoric – liquids, solids Organic Peroxides Corrosive to Metals Gases Under Pressure Water-Activated Flammable
Gases
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
27
Under New OSHA Definition…
OSHA incorporated new elements into its revised definition of Hazardous Chemical To include 3 classes of chemicals defined in its HCS that weren’t in GHS, Rev. 3
“Hazardous Chemical” means any chemical which is classified as a
1) Physical hazard; or2) Health hazard; or3) Simple asphyxiant; or4) Combustible dust; or5) Pyrophoric gas; or
6) Hazard Not Otherwise Classified (HNOC)
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
28
3 OSHA Specified Hazards - HazCom 2012
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
29
Labels
Product/Chemical Identifier
Six Main Elements
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
30
Labels
Product/Chemical Identifier
Supplier Identifier
Six Main Elements
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
31
Labels
* Standardized under GHS
Product/Chemical Identifier
Supplier Identifier
Hazard Pictogram(s)*
Six Main Elements
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
32
Label Pictograms North America
Current North America (U.S. DOT/ Canada WHMIS) Systems
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
33
Label Pictograms – DOT and GHS
GHS PictogramsTransport Pictograms
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
34
Label Pictograms
Explosives
Self Reactive
Organic Peroxide
Flammable
Self Reactive
Pyrophoric
Self-Heating
Emits Flammable Gas
Organic Peroxides
Oxidizers
Gases UnderPressure
Acute Toxicity(Fatal or toxic)
Skin Corrosion
Corrosive to Metals
Serious Damage
to Eye
Carcinogenicity
Respiratory Sensitizer
Reproductive Toxicity
Target Organ Toxicity
Mutagenicity
Aspiration Toxicity
Skin & Eye Irritant
Dermal Sensitizer
Acute Toxicity (harmful)
Transient Target Organ Effects
Harmful to Ozone Layer (Not mandatory)
Environmental Toxicity
Health Hazard
Gas Cylinder
Exploding Bomb Flame Flame Over Circle
Corrosion
EnvironmentExclamation Mark
Skull and Crossbones
(Not mandatory)
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
35
Labels
* Standardized under GHS
Product/Chemical Identifier
Supplier Identifier
Hazard Pictogram(s)*
Signal Word
Six Main Elements
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
36
Labels
* Standardized under GHS
Product/Chemical Identifier
Supplier Identifier
Hazard Pictogram(s)*
Signal Word
Hazard Statement(s)*
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
37
Labels
* Standardized under GHS
** Standardized under HCS
Product/Chemical Identifier
Supplier Identifier
Hazard Pictogram(s)*
Signal Word
Hazard Statement(s)*
Precautionary Information **
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
38
Workplace Labeling
Employers May Continue to Use Current Workplace-Specific Labeling Systems If they contain required information If they are consistent with new classifications
Labels on Incoming Containers Must not be removed or defaced Unless immediately replaced
Workplace Labels Must be prominently displayed In English Other languages permitted (additionally)
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
39
Workplace Labeling
Best practice - Whenever possible, replicate the shipping label OSHA says your Workplace Labeling System + Employee Training
should = at least the Same Level of Understanding as Shipped Label
OSHA says you can:
Use GHS shipped label
Use current system, so long as it :
Accounts for GHS changes
Doesn’t present conflicting information (with GHS changes)
When combined with your training, provides at least the same level of understanding as GHS shipped label
Includes use of alternative labeling systems like NFPA or HMIS
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
40
Safety Data Sheets
Redefined as Safety Data Sheets (SDS) GHS includes 16-part format Essentially the ANSI Standard
Several Sections are not Mandatory Sections 12-15
Ecological information Disposal considerations Transport information Regulatory information
Outside of OSHA’s jurisdiction
New Appendix D Details what is to be included in each section
=
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
41
SDS – Headings
1. Identification
2. Hazard(s) Identification
3. Composition/Ingredient Information
4. First-Aid Measures
5. Fire-Fighting Measures
6. Accidental Release Measures
7. Handling and Storage
8. Exposure Control/ Personal Protection
9. Physical & Chemical Properties
10.Stability & Reactivity
11. Toxicological Information
12.Ecological Information
13.Disposal Considerations
14.Transport Information
15.Regulatory Information
16.Other Information
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
42
SDS – Key Changes
Section 2 – Hazard(s) Identification GHS Classification Pictograms Signal Word Hazard
Statement Precautionary
Statement
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
43
SDS – To Do
Make sure staff is on the lookout for new, GHS formatted SDSs – especially for chemicals you regularly receive
Talk to your chemical suppliers and ask about their plans to transition to GHS – the sooner switch over happens…the easier it will be on us all
Be in active preparation mode for GHS training. Have a plan and make sure employees are ready to read the GHS SDSs and labels
Don’t forget SARA obligations: update local and state emergency response agencies when new chemical hazard information becomes available
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
44
Pretty much everyone who “uses” hazardous chemicals has some responsibility…
some more than others
Who’s Affected?
Chemical Manufacturers have some work to do around re-classifying chemicals, and then re-authoring MSDSs, labels and warnings to make them GHS compliant
Resellers, Distributors, Importers get new MSDSs and labels ASAP & distribute to customers
Employers...
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
45
Inventory your on-site chemicals
Make sure you have a complete library of MSDSs
Employers...
Have an HCS plan!
Maintain a checklist of key plan components
Review it annually, at least
Prepare yourself for the eventual MSDS churn
If you’re still using paper, consider transitioning to electronic system
Make sure your secondary labeling system is GHS compliant
Start developing a training plan for your employees
Stay current on OSHA Federal
State & local
Keep an eye on GHS Key dates
Impact on your plan
Request GHS compliant SDSs from chemical vendors
Ensure staff is on the lookout for SDSs with new shipments
Stay SARA compliant
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
46
Penalties for Noncompliance Are Very Real
From 2009 – 2012 OSHA cited over 24,000 instances of HCS violations in workplaces across the United States
#2 on OSHA’s top 10 list of most frequently cited compliance standards for 2012 Source: www.OSHA.gov
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
47
Costs Add Up Quickly
Fines
Potential Risk & Liability
Downtime & Internal Disruption
Lost Revenues
Negative Press & Impact to Corporate Image
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
48
Negative Corporate Image
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
It’s not just about…
49
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
Avoiding citations…
50
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
…and fines51
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
it’s also about…52
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
our employees…
53
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
our customers…54
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
our community…55
Copyright © 2001-2013, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
57
[email protected]@MSDSonline.com
Questions