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4/21/2011
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April 19, 2011 WebinarThis webinar addressed the Hazard Communication Standard and
the impact that OSHA’s proposed adoption of the Globally
Harmonized System (GHS) will have. It discussed that the GHS will
require everyone to update their HazCom training and paperwork.
It also discussed NECA’s resources available to assist in compliance
and accident prevention (i.e. NECA’s Safety Expert System
eSafetyLine software).
A copy of the PowerPoint file has been posted on the NECA
eSafetyLine software website. It is available free to all
subscribers. If you are currently registered for eSafetyLine, you can
access it under the training section in the Accident reporting
module. If you are not registered for eSafetyLine, you can contact
NECA at for more information on how to subscribe to eSafetyLine.
National Electrical Contractors Association
Bethesda Metro Center, Suite 1100
Bethesda, MD 20814
Phone: (301) 657-3110
Fax: (301) 215-4500 www.necanet.org
GHS – Changes to
the Standard that
Changed Safety
Diane Kelly ([email protected])
Joe O’Connor ([email protected])
800.745.4818
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� Right to Know
� First enacted 25 November 1983◦ Construction -1986
� Modified with minor changes and technical amendments took effect 11 March 1994
� 29 CFR 1910.1200/ 1926.59
� To ensure that chemical hazards in the workplace are◦ Identified
◦ Evaluated
� To pass this information to employers and employees
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� Information is to be communicated by a comprehensive Hazard Communication program including◦ Container labeling and other forms of warning
◦ Material Safety Data Sheets (MSDSs)
◦ Employee training
� The standard is made up of 6 categories:◦ Hazard Determination
◦ MSDSs
◦ Labeling and other forms of warning
◦ Employee Information and Training
◦ Written HazCom Program
◦ Trade Secrets
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� Employers are required to identify and evaluate all chemicals in the workplace
� Evaluation is based on ◦ Listed Hazards
◦ Defined Hazards
� Exempt chemicals◦ Wood and wood products (except wood dust)
◦ Regulated hazardous waste
◦ Tobacco products
◦ Food
◦ Drugs
◦ Cosmetics
◦ Alcoholic beverages
◦ Agricultural or vegetable seed treated with pesticides
◦ Various types of pesticides
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� All hazardous chemicals must be inventoried◦ MSDS obtained for each
� Obtained from chemical supplier, manufacturer or importer
� All information must be in English
� Must be available to employees working with or near hazardous chemicals
� MSDS◦ Contain specific chemical hazard information like� Physical hazard
� Health hazard
� Routes of entry
� Exposure limits
� Precautions for safe use and handling
� Spill clean-up procedures
� PPE
� Emergency and First Aid procedures
� Name, address, phone number of chemical manufacturer
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� Container of all chemicals must be labeled ◦ Identity of chemical
� Can be common or trade name
◦ Appropriate hazard warnings
� Words, pictures, symbols or any combination
� Physical AND health hazards
� Hazard warning◦ Not intended to be only or most complete source of information
◦ Brief statement of hazardous effects
� “Flammable”, “Causes lung damage”
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� Exceptions◦ Transferring Chemicals
� Break large quantity down into smaller usable amounts
� Smaller containers must be labeled with identity and potential hazards
� If transferred amount is used immediately by ONE employee during ONE work shift- label is NOT needed
� Exceptions◦ Special Emissions
� Signs, poster or other materials must warn employees about hazards of welding areas
� Employees exposed to emissions and fumes as well as areas where carbon monoxide is emitted
◦ Replacing Labels
� Labels must be replaced when they
� Become soiled
� Become unreadable
� Fall off
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� Employers must provide employees with◦ Effective information
◦ Training
� Training must occur◦ Before initial assignment
◦ Whenever a new Physical or Health hazard is introduced
� Training should include◦ Methods and observations used to detect the presence or release of chemical, physical and health hazards
◦ Physical and health hazards of chemicals in the work area
◦ Labeling and MSDS explanation
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� Training should include:◦ Protective measures
� PPE
� Gloves, face shields, foot gear, full body suits, respirators
� Safe Work Practices
� Keeping containers labeled, using tools instead of hands to apply chemicals, storing and transferring chemicals appropriately
� Emergency Procedures
� Eye station location, when or when not to flush chemical burns with water, location of MSDSs
� Employers must fully document any actions taken to comply with all parts of the standard
� List person(s) responsible for each area of the program
� Copy of program must be made available upon request to ◦ All employees
◦ OSHA officials
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� GHS was developed and adopted by UN◦ December 2002
◦ “Purple Book”
� Globally Harmonized System of Classification and Labeling of Chemicals
� Began as an “Action Program” at UN Conference on Environment and Development- 1992
� Initial goal◦ Produce new harmonized system by 2000
◦ Establish groups to analyze current systems and develop new one
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� Establishes new rules for hazardous chemicals◦ Transportation
◦ Workplace Use
◦ Consumer Use
� New MSDS◦ Now called Safety Data Sheets (SDS)
� Set requirements and new hazard symbols
� Comprises standards for◦ Classifying chemicals
◦ Symbols for hazards
◦ Labeling requirements
◦ SDS requirements
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� GHS will cover most hazardous chemicals (excluding wastes) in a system looking at ◦ Physical Hazards
� Flammability, corrosivity
◦ Health Hazards
� Both immediate and long-term
◦ Environmental Hazards
� Ozone and aquatic environment
� Different countries have different systems for classification and labeling
� Several different systems exist within ONE country◦ DOT
◦ OSHA
◦ EPA
◦ NFPA
◦ FDA
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� Meant to establish a SINGLE system for identifying hazardous materials and warning users
� Replace all the different regulations covering different countries and different uses of the same chemical
� Hoped to ◦ Improve safety
◦ Decrease supplier costs
◦ Make international shipment and sales of chemical products easier
◦ Ensure all users have the same basic standard of protection
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� There are 2:◦ Classification of the hazards of chemicals
� GHS provides guidance on classifying pure chemicals and mixtures according to its criteria and rules
◦ Communication of the hazards and precautionary information
� Labels
� With the GHS labels will contain standardized information
� Safety Data Sheets (SDS)
� 16 sections in set order with standardized information
� Based on a “Building Block” concept◦ Made up of standardized elements
◦ Appropriate “blocks” or elements can be selected
� Standardization◦ Hazard statements
◦ Hazard symbols
◦ Precautionary statements
� Possible in the future
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� In the workplace (OSHA) most elements (“blocks”) will be adopted◦ GHS Physical and Health hazard criteria
◦ Labels with harmonized core information
� Signal words, hazard statements
◦ SDS
◦ Employee training to help ensure effective communication
� When the GHS is implemented in a sector, coverage must be consistent◦ You can’t pick and choose which parts you want
� DOT cannot adopt GHS then say it wants to use its signal words but not use the standardized hazard statements
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� GHS establishes common system of chemical classification◦ “Test method neutral”
◦ Allows use of already available data
� “Tiered” approach for the classification of mixtures◦ First Choice
� Classify mixture based on the data available for the specific mixture
◦ Second Choice
� Use “bridging” principle
� Estimates the hazard based on ingredient information
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� Classifies according to 3 major hazard groups◦ Physical
◦ Health
◦ Environmental
� Within each hazard group there are classes
� Within each class there are categories
� For example◦ Group- Physical Hazard
� Class- Flammable Liquids
� Categories- 1-4 based on a liquid’s flashpoint and initial boiling point
Category Criteria
1 Flash point < 23°C and initial boiling point ≤ 35°C (95°F)
2 Flash point < 23°C and initial boiling point > 35°C (95°F)
3 Flash point ≥ 23°C and ≤ 60°C (140°F)
4 Flash point ≥ 60°C (140°F) and ≤ 93°C (200°F)
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� Now, labels for the same product have very different looks and information depending on◦ Target audience
� Consumer
� Transportation
� Workplace
◦ Location
� US vs. Canada vs. EU
� Workplace Label◦ Performance oriented
◦ Straightforward information
Figure 4.1ToxiFlamTOXIC
COMBUSTIBLE LIQUID ANDVAPOR
My Company, My Street, MyTown NJ00000
Tel. 444 999 9999
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ToxiFlam (Contains XYZ)
WARNING! HARMFUL IF SWALLOWED, FLAMMABLE LIQUID AND VAPORDo not taste or swallow. Do not take internally. Wash thoroughly after handling. Keep away from heat, sparks and flame. Keep container closed. Use only with adequate ventilation.FIRST AID: If swallowed, do NOT induce vomiting unless directed to do so by medical
personnel. Never give anything by mouth to an unconscious person.In case of Fire, use water fog, dry chemical, CO2, or alcohol foam. Water may be
ineffective.Flash Point = 120°F. Residue vapor may explode or ignite on ignition; do not cut, drill,
grind, or weld on or near the container. See Material Safety Data Sheet for further details regarding safe use of this product.
My Company, My Street, MyTown NJ 00000 Tel. 444 999 9999
ANSI Z 129.1 Precautionary Labeling Standard•Includes many of the GHS elements
� GHS label elements◦ Standardized
◦ Directly related to the endpoints/end-user and hazard level
◦ Symbols/ Hazard Pictograms *
� Convey health, physical and environmental hazard information
� Assigned to hazard class and category
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◦ Signal words *
� Danger or Warning
� Used to emphasize hazards
� Indicates relative level of severity of hazard
◦ Hazard Statements *
� Standardized phrases assigned to a hazard class
� Describe nature of the hazard
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� Other GHS elements◦ Precautionary Statements and Pictograms *
� Supplements the hazard information, provides ways to minimize or prevent adverse effects
◦ Product Identifier/Ingredient Disclosure *
� Should match wording on SDS
� Chemical Identity
◦ Supplier Information *
◦ Supplemental Information- NON-Harmonized
� Not required or specified under GHS
� May be provided at discretion of manufacturer or distributor
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� Provides comprehensive information to help manage chemicals
� Enables employer to correctly protect workers
� Based on 16-heading format◦ Established by International Labour Organization (ILO)
◦ Used as the basis for ANSI MSDSs
� Headings, sequence and content is standardized
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� Section Headings1. Identification
2. Hazard(s) Identification
3. Composition/ information on ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/PPE
9. Physical and chemical properties
10.Stability and reactivity
11.Toxicological information
12.Ecological information
13.Disposal considerations
14.Transport information
15.Regulatory information
16.Other information
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� Biggest change from the ILO SDS format to the new GHS format◦ Section 2 and 3 order is switched
� #2 Hazard Identification was 3
� #3 Composition was 2
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� At present, many suppliers use many different formats◦ They must be rewritten
� The most current ANSI MSDS standard (ANSI Z 400.1-2004) DOES reflect the GHS format◦ This format CAN be used
◦ Content would have to be rewritten because of GHS Hazard Criteria
� 2005- OSHA developed modifications to current HCS needed to adopt GHS
� 2006- Advanced Notice of Proposed Rulemaking (ANPR)◦ Provided full history of GHS
◦ Information on how the GHS would affect the current HCS
◦ Series of questions that OSHA needs answered to complete further steps in the rulemaking process
� 2009- published completed Notice of Proposed Rulemaking (NPR) to incorporate GHS into current HCS
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� Key points of 2009 NPR◦ Confirmation OSHA will adopt all GHS Physical and Health hazard criteria except
� Acute Toxicity Category 5
� Aspiration Hazard Category 2
� Irritation Category 3
◦ Definition of “Unclassified Hazards”
� Includes hazards not presently addressed in current HCS and any new hazards that will be added
� Key points of 2009 NPR◦ Special coverage for “Simple Asphyxiants”
◦ “Combustible Liquid” has been removed
◦ Flammable Liquids Safety Standard has been revised with new classification criteria
◦ Retraining will be required within 2 YEARS after publication of final rule
◦ FULL COMPLIANCE with new HCS, including GHS, required within 3 YEARS after publication of the final rule
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� Issues OSHA has requested input◦ Should precautionary statements used on a label be those specified in the GHS or can label preparers be allowed to develop tier own language
◦ Should a database of chemicals classified according to the GHS be developed to assist manufacturers and importers with their own GHS classifications
◦ Should implementation of the NPR be mandatory or should OSHA only adopt certain parts of the new GHS but leave the remaining parts of the new HCS voluntary
� 2009 NPR allowed for a 90-day comment period
� Early 2010- Public hearings were held
� OSHA is now in the process of finalizing its Final Rule to adopt the GHS into current HCS
� Final rule is expected to be published AUGUST 2011
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End of Session
For Help Contact
Intec, Inc.800.745.4818
Joe O’Connor, [email protected]
Diane Kelly [email protected]
