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Review current WHMIS and OSHA supplier label requirements; Compare WHMIS and OSHA label requirements to the GHS label requirements; Provide some insight into how you can write WHMIS- and OSHA-compliant labels today with an eye to GHS implementation.This presentation was delivered as a webinar on January 31, 2012, by Jessie Callaghan, Senior Technical Specialist at the Canadian Centre for Occupational Health and Safety. To listen to the recording of the webinar, for free, register at: https://www1.gotomeeting.com/register/358197609
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www.ccohs.ca
WHMIS and OSHA Labels
Presented by:Jessie Callaghan
Senior Technical Specialist
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Today’s Presentation
Review current WHMIS and OSHA supplier label requirements
Compare WHMIS and OSHA label requirements to the GHS label requirements
Provide some insight into how you can write WHMIS- and OSHA-compliant labels today with an eye to GHS implementation
Canadian Centre for Occupational Health and Safety www.ccohs.ca
WHMIS Supplier Label
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Canadian Centre for Occupational Health and Safety www.ccohs.ca
New GHS Label Elements
Chemical identity (listing of hazardous ingredients)
Signal word (Danger or Warning)
Canadian Centre for Occupational Health and Safety www.ccohs.ca
WHMIS Hazard Symbols vs. GHS Pictograms
Canadian Centre for Occupational Health and Safety www.ccohs.ca
“A statementstatement identifying a hazardhazard that may arise from the nature of the controlled product or the class, division or subdivision of controlled products.”
“A phrase assignedassigned to a hazard class and category that describes the nature of the hazards of hazardous product, including, where appropriate, the degree of hazard.”
WHMIS Risk Phrases GHS Hazard Statements
Canadian Centre for Occupational Health and Safety www.ccohs.ca
“A statement identifying a hazardhazard that may arise from the nature of the controlled product or the class, division or subdivision of controlled products.”
“A phrase assignedassigned to a hazard class and category that describes the nature of the hazards of hazardous product, including, where appropriate, the degree of hazard.”
WHMIS Risk Phrases GHS Hazard Statements
It may be possible to use a GHS Hazard Statement as your WHMIS Risk Phrase if it accurately describes the product’s hazards.
Canadian Centre for Occupational Health and Safety www.ccohs.ca
A product with a flash point (closed cup) of 65ºC is a WHMIS “combustible liquid” AND a GHS “combustible liquid” (Cat. 4).
A product with a flash point (closed cup) of 50ºC is a WHMIS “combustible liquid” AND a GHS “Flammable liquid and vapour” (Cat. 3).
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Using the GHS Hazard Statement “Fatal if swallowed” for a product classified as WHMIS D1A (oral) will take you one step closer to being GHS ready.
Canadian Centre for Occupational Health and Safety www.ccohs.ca
WHMIS Precautionary Measures“Precautionary measures to be followed when handling, using or being exposed to the controlled product.”
GHS Precautionary Statements“Recommended measures that should be taken to minimise or prevent adverse effects resulting from exposure to a hazardous product, or improper storage or handling of a hazardous product.”
Canadian Centre for Occupational Health and Safety www.ccohs.ca
WHMIS Precautionary Measures
WHMIS First Aid Measures“Where appropriate, first aid measures to be taken in case of exposure to a controlled product.”
GHS Precautionary Statements“Recommended measures that should be taken to minimise or prevent adverse effects resulting from exposure to a hazardous product, or improper storage or handling of a hazardous product.”
Statement Types:1. General2. Prevention3. Response (fire, first aid,
accidental release)
4. Storage5. Disposal
Canadian Centre for Occupational Health and Safety www.ccohs.ca
GHS Precautionary Statements Serious Eye Damage/Eye Irritation – Category 2(A)
Hazard Statement: Causes serious eye irritation.
Prevention: Wash…thoroughly after handling. Wear eye protection/face protection.
Response: IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. If eye irritation persists: Get medical advice/attention.
Storage: None recommended.
Disposal: None recommended.
Canadian Centre for Occupational Health and Safety www.ccohs.ca
GHS Precautionary Statements Gas Under Pressure – Compressed Gas
Prevention: None recommended
Response: None recommended
Storage: Protect from sunlight. Store in a well-ventilated place.
Disposal: None recommended
Canadian Centre for Occupational Health and Safety www.ccohs.ca
WHMIS Label Elements Not Required by the GHS
Hatched border
Reference to MSDS
These elements must be
present on a WHMIS-
compliant label today.
It is not known if they will be
retained following
implementation of the GHS in
WHMIS.
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Canadian Centre for Occupational Health and Safety www.ccohs.ca
WHMIS Workplace Label
Product Identifier
Information for the safe handling of the product
A statement that the MSDS is available
There are no GHS specifications for a workplace
label.
Canadian Centre for Occupational Health and Safety www.ccohs.ca
OSHA-Compliant Label
Identity of hazardous chemical
Name and address of responsible party
Appropriate hazard warnings
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Canadian Centre for Occupational Health and Safety www.ccohs.ca
ANSI Standard (Z129.1)
Identification of the chemical product
Identification of its hazardous component(s)
Name, address, telephone number of the manufacturer, importer or other responsible party
Signal word (Danger, Warning, Caution)
Statement(s) of hazard(s)
Precautionary measures
Instructions in case of contact or exposure (first aid)
Antidotes, and notes to physician
Instructions in case of fire
Instructions in case of spill or leak
Instructions for container handling and storage
Reference(s) to additional labeling/other documents
Canadian Centre for Occupational Health and Safety www.ccohs.ca
OSHA permits the use of graphics: pictures, symbols, or combination thereof appearing on a label or other appropriate form of warning which convey the specific physical or health hazard(s), including target organ effects, of the chemical(s) in the container(s).
Source: Fact Sheet #4 Labeling – OSHA vs. GHS (Jan. 2010). Produced by SCHC-OSHA Alliance GHS Information Sheet Workgroup. Available at www.schc.org.
Pictograms
Canadian Centre for Occupational Health and Safety www.ccohs.ca
OSHA Position
“… as long as the EU GHS label contains the information required by the HCS, OSHA will
consider the EU GHS label sufficient.”
Source: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATI
ONS&p_id=27218
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Start using GHS Hazard and Precautionary Statements now, as appropriate, adding any OSHA-specific information required.
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Canadian Centre for Occupational Health and Safety www.ccohs.ca
Preparing for Change
• Compare the WHMIS and/or OSHA hazards of your products to the GHS hazards.
• Start transitioning your label content as you update or write new labels, as appropriate.