Hazard Communication and the Globally Harmonized System (GHS) Training

Presented by PLANET*

*The Professional Landcare Network (PLANET) provides this PowerPoint presentation

as a service to its members in furtherance of PLANET’s mission. PLANET is not

responsible for, and expressly disclaims all liability for, damages of any kind arising

out of use, reference to, or reliance on any information contained within the

presentation. Please refer to OSHA requirements to provide this training to your

employees. The following information is a general review of the subject matter.

 Please consult with a subject matter expert for compliance review and advice. 

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IntroductionThis presentation contains information about employer responsibilities with regards to the revised Hazardous Communications Standards (also known as the Globally Harmonized System (GHS) of Classification & Labeling of Chemicals) and for use in training employees on the new label elements and safety data sheet format associated with GHS.

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Table of ContentWhy did OSHA align the HCS with GHS? 4

Benefits of Adopting the GHS 5

Purpose 7

How Hazard Communication Works 8

Employer Responsibilities – Labels 9

Employer Responsibilities – SDS 11

Checklist for Employer Compliance 12

Final Rule 14

Phase-in-Period for revised Hazard Communication Standard 15

Training Outlineo Lesson 1: Label elementso Lesson 2: Safety Data Sheet Format

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Additional Training Resources 38

Assessment and Evaluation 40

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To provide a common, coherent approach to classifying and communicating chemical hazards. This approach includes:

» Harmonized (standardized) definitions of hazards

» Specific criteria for labels

» Harmonized (standardized) format for safety data sheets

Why did OSHA align theHCS with GHS?

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Benefits of Adopting the GHS

• Increase the quality and consistency of information provided to workers, employers and chemical users.»Reduce confusion/Increase

comprehension of hazards.» Improve downstream risk

management.»Facilitate training.»Help address literacy problems.

• Other benefits include facilitation of international trade in chemicals

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Note:OSHA is moving forward to change the

MSDS and all chemical labels to comply with GHS; however, the EPA will not require any changes to pesticide labels.

This may cause confusion since the signal word on the OSHA-regulated SDS will not match the signal word on the EPA-regulated pesticide label.

“Danger” and “Warning” are the only two signal words that will appear on the revised HCS; Pesticide labels will continue to use the current signal words “Caution,” “Warning,” and “Danger.”

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PurposeOSHA requires that by Dec. 1, 2013, each

person in your company who deals with chemicals must be verifiably trained on:

Label elements of non-pesticide chemicals The new SDS format applicable to both pesticides

and non-pesticidesOSHA requires this to ensure that the

hazards of all chemicals, produced or imported, are classified and that information about their hazards is given to employers and their employees.

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How Hazard Communication Works

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Employer Responsibilities - Labels Maintain labels on the containers, including , but

not limited to, tanks, totes and drums, so they continue to be legible and the pertinent information is not defaced (i.e., fade, get washed off) or removed in any way.

Re-label items if the labels are removed or defaced. Labels must be legible, in English, and prominently

displayed. Other languages may be displayed in addition to English.

General OSHA requirements for workplace labeling have not changed.

Employers have option to create their own workplace labels.

Employer with workplace system of labeling that meets the requirements of HazCom 1994 may continue to use this system as long as it provides employees with the information on all of the health and physical hazards of the hazardous chemical.

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Employer Responsibilities - Labels If an employer chooses to use the GHS

pictograms, these pictograms may have a black border, rather than a red border (manufacturers, importers, or distributors shipping or transporting hazardous chemicals must to use pictograms with red border with a black hazard symbol on a white background).

Employer may use additional instructional symbols, not included in OSHA’s HCS pictograms (e.g., a person wearing goggles or an environmental or PPE pictogram) on workplace labels.

Note: If an employer transfers hazardous chemicals from a labeled container to a portable container that is only intended for immediate use by the employee who performs the transfer, no labels are required for the portable container.

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Employer Responsibilities - SDS

• Designate person to obtain SDS• Maintain SDS

• (e.g., Notebooks, electronic, back-up system, access)

• Know procedures to follow to obtain SDS• Follow procedures for updating SDS

• Chemical manufacturers and importers• Have SDS readily accessible and available

upon request• (e.g., Main offices, work areas, mobile

locations)

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Checklist for Employer Compliance

• Obtain a copy of the rule• Read and understand the

requirements• Assign responsibility for tasks• Prepare an inventory of chemicals• Ensure containers are labeled• Obtain SDS for each chemical• Prepare written program (when

required under new program you should update your old program)

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Checklist for Employer Compliance

• Make SDS available to workers• Conduct training of workers

• Establish procedures to maintain current program

• Establish procedures to evaluate effectiveness

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Final RuleThe final rule was published in

the Federal Register on March 26, 2012 and became effective on May 25, 2012. The rule can be found at

◦https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=22607

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Phase-in period for the revised Hazard Communication Standard

*This date coincides with the EU implementation date for classification of mixtures

Effective Completion Date

Requirement(s) Who

December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format.

Employers

June 1, 2015* Compliance with all modified provisions of this final rule, except:

Chemical manufacturers, importers, distributors and employers

December 1, 2015 The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label

June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

Employers

Transition Period to the effective completion dates noted above

May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both

Chemical manufacturers, importers, distributors, and employers

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Training OutlineLesson 1: Label elements

◦What is HCS definition of a label◦Type of information employee would

expect to see on the new labels.◦ How employee might use that

informationLesson 2: Safety Data Sheet

Format◦Standardized 16-section format ◦Type of information found in the

various sections

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Lesson 1: Label elementsHCS definition of a label:

• An appropriate group of written, printed or graphic informational elements concerning a hazardous chemical that are affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging.

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Lesson 1: Label elementsLabels for a hazardous chemical

must contain:

• Name, Address, and Telephone Number

• Product Identifier• Signal Word• Hazard Statement(s)• Precautionary Statement(s)• Pictogram(s)

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Sample Label

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Sam

ple

Label

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Sam

ple

Label

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Lesson 1: Label elements (instructor slide)Labels for a hazardous chemical must contain:

Name, Address, and Telephone Number of

the chemical manufacturer, importer or other responsible party.

Product Identifier: the chemical name, code number or

batch number. (the manufacturer, importer or distributor can

decide the appropriate product identifier, but the same product

identifier must be both on the label and in section 1 of the SDS.

Signal Word to indicate the relative level of severity of the hazard and alert the reader to a potential hazard.

• “Danger” and “Warning” are the only two words used as signal words;

there will only be one signal word on the label, no matter how

many hazards a chemical may have.

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Lesson 1: Label elements (instructor slide – cont.)Labels for a hazardous chemical must contain:

Hazard Statement(s) to describe the nature of the

hazard(s) of a chemical, including where appropriate the

degree of hazard.

• For example: “Causes damage to kidneys through prolonged or

repeated exposure when absorbed through the skin.”

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Lesson 1: Label elements (instructor slide – cont.)Labels for a hazardous chemical must contain:Precautionary Statement(s)* describe

recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to or improper storage or handling of the hazardous chemical. There are four types of precautionary statements:

1. Prevention (to minimize exposure)

2. Response (in case of accidental spillage or exposure emergency response and first-aid)

3. Storage4. Disposal

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Lesson 1: Label elements (instructor slide – cont.)Labels for a hazardous chemical must

contain:Precautionary Statement(s)* – example:A chemical presenting a specific target organ toxicity would include

the following on the label:

“Do not breathe dust/fume/gas/mist/vapors/spray. Get medical

advice/attention if you feel unwell. Dispose of contents/container

in accordance with local/regional/national and international

regulations.”

*See OSHA Brief on

Hazard Communication Standard: Labels and Pictograms for more

details.

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Lesson 1: Label elements (instructor slide – cont.)Examples of Precautionary Statements:Keep container tightly closed. Store in a cool,well-ventilated place that is locked.

Keep away from heat/sparks/open flame. No smoking.

Only use non-sparking tools.

Use explosion-proof electrical equipment.

Take precautionary measures against static discharge.

Ground and bond container and receiving equipment.

Do not breathe vapors.

Wear protective gloves.

Do not eat, drink or smoke when using this product.

Wash hands thoroughly after handling.

Dispose of in accordance with local, regional, national,international regulations as specified.

In Case of Fire: use dry chemical (BC) or Carbon Dioxide (CO2) fire extinguisher to extinguish.

First Aid If exposed call Poison Center.

If on skin (or hair): Take off immediately any contaminatedclothing. Rinse skin with water.

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Lesson 1: Label elements (instructor slide – cont.)Labels for a hazardous chemical must

contain:

Pictogram(s) graphic symbols used to communicate specific information about the hazards of a chemical. indicate the relative level of severity of the hazard and alert the reader to a potential hazard.

• “Danger” and “Warning” are the only two words used as

signal words; there will only be one signal word on

the label, no matter how many hazards a chemical may

have.

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Lesson 1: HCS Pictograms and HazardsOSHA has designated eight pictograms

under this standard for application to a hazard category (see following slide).

OSHA’s required pictograms mustBe in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame sufficiently wide enough to be clearly visible. ◦ A square red frame set at a point without a

hazard symbol is not a pictogram and is not permitted on the label.

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Lesson 1: HCS Pictograms and Hazards

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Lesson1: How Employee might use the labels in the workplace

To ensure proper storage of hazardous chemicals.

To quickly locate information on first aid when needed by employees or emergency personnel.

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Lesson 1: How elements on label work together

Some chemicals may have multiple hazards, different pictograms are used to identify the various hazards. You should expect to see the appropriate pictogram for the corresponding hazard class.

When there are similar precautionary statements, the one providing the most protective information will be included on the label.

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Lesson 2: Safety Data Sheet FormatHCS requires chemical manufacturers,

distributors, or importers to provide Safety Data Sheets (SDS, formerly known as Material Safety Data Sheets (MDS)) to communicate the dangers of hazardous chemical products.

As of June 1, 2015, the HCS will require new SDS to be in a uniform format and include the following 1-16 section numbers, with the headings, and associated information:

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Lesson 2: SDS Format Sections

Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.

Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.

Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.

Section 4, First-aid measures includes important symptoms/effects, acute, delayed; required treatment.

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Lesson 2: SDS Format Sections

Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.

Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.

Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.

Section 8, Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).

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Lesson 2: SDS Format SectionsSection 9, Physical and

chemical properties lists the chemical’s characteristics.

Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.

Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.

Section 12, Ecological information*

Section 13, Disposal considerations*

Section 14, Transport information*

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Lesson 2: SDS Format Sections Section 15, Regulatory Information,* this section documents the chemical’s classification under federal regulations such as the Toxic Substances Control Act, the Clean Water Act and the Superfund Amendments and Reauthorization Act among others. Special Information for pesticides included in this section. EPA has instructed manufactures/suppliers to insert the required FIFRA label hazard information in this section. If the pesticide label signal word is different from the signal word on the SDS, (new standard does not use “Caution”) this is where it is explained. Section 16, Other information, includes the date of preparation or last revision.*Note: Since other Agencies regulate this

information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)).

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Lesson 1 & 2: Wrap-upSummarize important points.Allow time for questions.

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Additional Training ResourcesOSHA Hazard Communication

website: https://www.osha.gov/dsg/hazcom/index.html

Federal Register Hazard Communication Rule: https://www.osha.gov/FedReg_osha_pdf/FED20120326.pdf

Hazard Communication Safety Data Sheets Quick Card: https://www.osha.gov/Publications/HazComm_QuickCard_SafetyData.html

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Additional Training ResourcesHazard Communication

Standard QuickCards

https://www.osha.gov/dsg/hazcom/ghsquickcards.html

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Assessment and Evaluation1. GHS stands for:

a. Globally Harmonized System b. Good Health Safety c. Global Health Strategies2. The GHS system provides for:

a. Improved understanding and communication b. More OSHA citations and penalties3. A chemical in hazard category 4 represents which category of hazard?

a. Most hazardous category in that hazard class b. Least hazardous category in that hazard class4. The words “danger” or “warning” are examples of:

a. Signal words c. Pictograms b. Hazard statements d. Precautionary statements

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Assessment and Evaluation5. A workplace label must always contain the name, address, and telephone number of the chemical’s manufacturer or supplier.

a. True b. False 6. OSHA will strictly enforce Environmental requirements.

a. True b. False7. A chemical in a secondary container that has not been labeled with a workplace label will still be in compliance, provided the worker who labeled it will be the same worker to use the chemical the following workday.

a. True b. False 8. Safety Data Sheets must follow a uniform format consisting of 18 sections of information.

a. True b. False

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Assessment and Evaluation

9. Businesses that have employees who travel for work at off-site locations are

required to keep Safety Data Sheets in every vehicle.

a. True b. False

10. Under the requirements of the GHS system, manufacturers will transmit

information about hazardous chemicals through:

a. Material Safety Data Sheets b. Safety Data Sheets

11. The responsibility for classifying chemicals is a requirement for:

a. Assigned by the manufacturer, producer, or importer b. Assigned

by an employer, if desired c. both

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Assessment and Evaluation 1. Answer a: Globally

Harmonized System 2. Answer a: Improved

understanding and communication 3. Answer b: Least hazardous

category in that hazard class 4. Answer a: Signal words 5. Answer b: False 6. Answer b: False 7. Answer b: False 8. Answer b: False (16)

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Assessment and Evaluation 9. Answer b: False 10. Answer b: Safety Data Sheets 11. Answer a: Assigned by the

manufacturer, producer, or importer