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 Presentation
Citation preview
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