NW HELP Group Meeting - August 14, 2013 Presented by Chris Antony, EH&SO IDRI, Seattle, Washington 08/09/2013 ©2013 NW HELP Group: Permission to use granted

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GHS Implementation: An Action Plan for Bioresearch Settings

NW HELP Group Meeting - August 14, 2013 Presented by Chris Antony, EH&SO IDRI, Seattle, Washington

08/09/2013©2013 NW HELP Group: Permission to use granted provided attribution is shown

©2013 NW HELP Group: Permission to use granted provided attribution is shown

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Goal of this Presentation:Enable you to develop and implement a GHS Action Plan for your Bioresearch Organization

08/09/2013

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Closed Course: Professional Drivers Only◦ “Explanations create comprehension but plans create action”◦ BUT – If I miss it, get it wrong, or don’t hit the goal – please say something

This presentation is distilled from a number of sources;◦An excellent 08/01/13 presentation by Denise Deeds, CIH, at UW’s

NW Center for Occupational Health and Safety◦ Information from Pamela Edwards, IH, with WA L&I, DOSH◦UN Publication on GHS 5th revised edition◦Websites for OHSA, NIOSH, WISHA, CDC/NIH◦ Very good SDS vs MSDS Presentation by staff at JK, Inc., Houston◦ GHS Implementation Course, National Safety Council◦ Additional resources listed under Toolkit


Disclaimers & Credits

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What we will be discussing today

Not Covering How to ‘assemble’ an SDS Non-Lab GHS implementation GHS impacts to other Regs DOT issues A bunch of other stuff

Covering UN GHS Development GHS Implementation in US Brief Recap of 1900.1200/1450 WA State Implementation Detailed Review of GHS parts◦ Labels ◦ Pictograms & Hazard revisions◦ SDS sections

Suggested Action Plan Ongoing Issues Toolkit & Resources Membership in WSACL

08/09/2013©2013 NW HELP Group: Permission to use granted provided attribution is

shown

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GHS Development Overview

1989 - ILO Convention on Safety in the Use of Chemicals at Work 1992 - Rio “Earth Summit” established 6 program areas on sound management

of chemicals - including harmonization of classification and labeling of chemicals 1994 - IOMC (Interorganization Programme for the Sound Management of Chemicals) The Coordinating Group for the Harmonization of Chemical Classification Systems led the effort. Technical Work:

◦ Physical Hazards - UN Experts on TDG◦ Health/Environmental Hazards - OECD◦ Hazard Communication – ILO

1994 - OHSA implements new HSC UN Adopted Basic GHS components and published “Purple Book” in December

2002, ◦ Rev 1: 2005, Rev 2: 2007, Rev 3: 2009, Rev 4: 2011 ◦ Rev 5: 2013 [see toolkit]


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GHS Integration into the US Regulatory Environment

CPSC (Consumer Labeling) changes are under consideration/development EPA (Pesticides) – 2004 White Paper, 10/06 stakeholder meetings, pursuing voluntary pilot

activities, working on interagency coordination. 4/9/12 issued PR Notice 2012-1 Guidance on how to comply with OSHA and EPA re: SDS

DOT adopted changes to regulations to implement the GHS in the transport sector and remain harmonized with the UN TDG – except DOT permits but does not require aquatic toxicity classification: retains the current system

OSHA’s Approach maintains the basic requirements of the current standard Only change those provisions such as HazCom that need to be changed to adopt the GHS “Right to Know” becomes “Right to Understand” Maintain or enhance the level of protection provided by the HCS [thus 2012 rev] looking at

scope of chemicals, hazards, information availability and workplace requirements Allow exemptions to GHS labeling requirement [list in toolkit] including Haz Waste, Bio

hazards (infectious only), Radiation (ionizing and non-ionizing), Consumer products only if used in consumer manner (e.g. Bleach)


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OHSA - Hazard Communication Standard 2012 [Verbatim text] (a) Purpose. (a)(1) The purpose of this section is to ensure that the

hazards of all chemicals produced or imported are classified, and that information concerning the classified hazards is transmitted to employers and employees. The requirements of this section are intended to be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 3. The transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, safety data sheets and employee training.

OHSA - Hazard Communication Standard 2012 [CTTC text]

1. Ensure chemical hazards are classified2. Transmit this info to employees via◦ Container labels – Pictograms!◦ Safety Data Sheets◦ Training

3. All info to be consistent with GHS


Hazard Communication Standard:OSHA 1900.1200 (Old = 1994 Revised = 2012)

Lab specific Regs are 1910.1450

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Under 1900.1450 the Lab HazCom =Post-GHS

‘Right to Understand”

Hazard Classification

A Chemical Hygiene Officer who is GHS Trained

A Chemical Hygiene Plan with GHS items addedUnderstanding Pictograms/new hazardsUnderstanding how to read an SDS

Document GHS Training

Label Chemicals: Decision on showing both GHS & Non-GHS

Retain MSDS, Replace with SDS as received, provide access


Pre-GHS“Right to Know”

Hazard Determination

A Chemical Hygiene Officer

A Written Chemical Hygiene PlanNPFA hazardsMSDS knowledge

Document Training

Label Chemicals in the LabUsed the Manufacturers’

Retain and provide MSDS access

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WA L&I: DOSH Implementation Compliance Dates Different◦ Employers train on GHS labels & SDS

Complete by JUNE 1, 2014 vs 12/1/13

◦ Manufacturers comply with labeling Complete by JUNE 1, 2015

◦ Distributors ship only GHS labels By DECEMBER 1, 2015

◦ Employers update HazCom By JUNE 1, 2016

WA Rulemaking effective◦ APRIL 15, 2013

Employer HazCom◦ WAC 296-800-170

New WAC Chapter◦ Update is 296-901-140◦ Essentially matches the

Federal version◦ WAC 296-839 (MSDS) not updated

GHS changes some 25 other WACs



GHS Parts1. Labels2. Pictograms and Hazard Classes3. SDS

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GHS

LabelsGoal: Understand the Six Parts




New GHS Labels draw all statements from existing text, listed by hazard class – this table is an example of the process


Our challenge is well illustrated by this table 1 is the new 4 4 is the new 1 “Pink is the new black”

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GHS

PictogramsGoal: Understand the Change to

Hazard Classification Represented by Each Pictogram




Hazard Categories within a Classification are determined by Data


Full definitions of each of the sub categories are in Appendix A


WARNING!!!!! REDUNDENCY

ALERT


Exploding Bomb says it all!Flame This is a complex set of hazards that includes high-use

materials for labs Gases, Aerosols, Liquids, and Solids


Oxidizing materials Gas = O2 and O3

Liquids = Nitric Acid, Chromic acid, Sodium Hypochlorite Solids = Chromate, Potassium Permanganate


Will be used in by two different Risk Categories Chemical/PhysicalRisk = e.g. Corrosive Metals Health Risk = e.g. Eye Damage


Remember: Category 4 = least hazardous condition


Environment Pictogram: “Dead Tree Dead Fish” No current standard for non-aquatic species e.g. Bees If it is a category 3 or 4 Environment = no symbol no signal word

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GHS

Safety Data SheetsGoal: Understand the Section changes and where to look for

needed data


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SAFETY DATA SHEET SECTIONSSection 1. Identification

Section 2. Hazard(s) identification

Section 3. Composition/information on ingredients

Section 4. First-Aid measures

Section 5. Fire-fighting measures

Section 6. Accidental release measures

Section 7. Handling and storage

Section 8. Exposure controls/personal protection

Section 9. Physical and chemical properties Section 10. Stability and reactivity Section 11. Toxicological information Section 12. Ecological information Section 13. Disposal considerations Section 14. Transport information Section 15. Regulatory information Section 16. Other information, including date of preparation or last revision




2808/09/2013





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A revised 2012 OHSA Hazard Communication Standard incorporates a UN based Global Harmonization System for chemical labeling and handling – WA State Adopts

New GHS Labels have 6 parts

Pictograms represent 9 hazard classifications distributed among three hazard groups: one used in two different groups

A 16 section Safety Data Sheet replaces the MSDS

08/09/2013

GHS Parts Recap!


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Lab Chem db’s need “agreed to” identifier: IDRI uses CAS◦ No standard identifer agreed-to at this point – what about mixtures?

Further GHS impacts to Lab operations may occur as WA’s State/Local Agencies adjust to GHS◦ Adjustment of APP, BECP, or other regs. ◦ Fire Dept Regs - Future impact on SFD HMIS classification (2009 fire code)

SDS Conversion by Chemical vendors has a long way to go◦ Informal survey of IDRI suppliers shows a broad range of progress

UN Two YR GHS Update process will cause additional changes◦ e.g. Combustible dusts [un-defined] now specifically addressed – change?◦ Status of Environmental hazards and implementation

08/09/2013

Ongoing Issues [Antony Commentary]

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By Sept 2 ◦ “Dig out” your written Hazard Communication Standard (whether it’s 1900.1200

or 1450) and review it – then decide if you will hold GHS training in 2013 or 2014 THEN set the date! (IDRI will be Training 10/22-26/13)

◦ You can’t train on subjects that you don’t understand so honestly spend a couple of hours reviewing the hazard classification changes – you’ll get everything else

◦ Determine how you will handle incoming new SDS’s within current system & retain copies of ‘old’ MSDS.

By Sept 30 ◦ CRITICAL – don’t wait to create GHS training materials even if you elect to do

the training in first half of 2014 – You’ll run out of time! This training should be KSS = Labels/Picto & Haz Class/SDS.

By Nov 30◦ Identify other GHS impacts to your organization [i.e. writing of in-house SDS’s] ◦ Think about being on a Beach in San Diego


Action Plan [Antony comments]


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1. A Detailed summary recap of Hazard Classifications by Pictogram Haz Class Summary Deeds.pdf Appendix A Detailed Hazard Classifications.pdf

2. Direct comparison of OSHA’s HCS 1994 v 2012 https://www.osha.gov/dsg/hazcom/side-by-side.html

3. UN Purple Book 5th Edition in pdf form4. Comparison of SDS new Format vs MSDS

MSDSvsSDS_McKelvey_Aug2012

5. Detailed Guidance for Writing an SDS GHS Presentation UW 080113 [Work by Denese Deeds]

08/09/2013

Tool Kit & Resources

https://www.osha.gov/dsg/hazcom/side-by-side.html



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Don’t be a Member of WSACL

Washington State Amateur Crastinator League

Turning Pro Right After This GHS Presentation!


Documents

NW HELP Group Meeting - August 14, 2013 Presented by Chris Antony, EH&SO IDRI, Seattle, Washington 08/09/2013 ©2013 NW HELP Group: Permission to use granted