AN OVERVIEW OF GLOBALLY HARMONIZED SYSTEM

(GHS)

TALON SAFETY, LLC

STATEMENT OF NEED(OSHA)

Multiple sets of requirements for labels and safety data sheets present a compliance burden for U.S. Manufacturers, distributors, and transporters.

Hazard information and worker safety will be enhanced, as the GHS will:

• Provide consistent information and definitions for hazardous chemicals;

• Address stakeholder concerns regarding the need for a standardized format for MSDS; and,

• Increase understanding by using standardized pictograms and harmonized hazard statements.

GHS will reduce confusion and thus reduce worker safety and health.

HAZCOM VS. GHS

There are many differences in the Hazard Communication System (HCS/HAZCOM) and the Globally Harmonized System (GHS).

It is recommended that you review the changes and the implementation as it specifically affects your organization.

HAZCOM

• Hazard Communication System– OSHA estimates:

• 7 million workplaces• 100 million employees• 945,000 hazardous chemical products

GLOBALLY HARMONIZED SYSTEM

– GHS –• Prepared and first implemented by United Nations

Economic Commission for Europe in 2003• The third revision was published in July 2009

GLOBALLY HARMONIZED SYSTEM

• Implementation – Current status

• NPRM Comment Period ended 12/29/2009• Hearing 03/31/2010• Post Hearing Comment period closed June 1,

2010• Estimated that a final rule will be issued within 18

months• Currently proposed 3 year implementation period

to allow industry to change systems, labels, data sheets

HAZCOM vs GHS

• System differences– A revision to the criteria for the classification

of chemical hazards– Changes in label requirements

• Mandatory use of standardized signal words, pictograms, hazard statements & precautionary statements

– A required format for Safety Data Sheets (SDS)

HAZCOM vs GHS

HAZCOM vs GHS

– New term definitions– Changes to employee training requirements– Additional OSHA standard modifications to be

consistent with GHS

• Flammable / Combustible liquids• Process Safety Management• Substance specific health standards

HAZCOM VS GHS

CLASSIFICAITON OF

CHEMICAL HAZARDS

HAZCOM vs. GHS

Chemical Identification - HCS

• Manufacturers or importers must assess the hazard of chemicals they produce or import and provide information to their employees about the hazardous chemicals to which they are exposed.

• Distributors must also transmit the required information to their employees.

Chemical Identification - GHS

• In addition to the requirements of the HCS, GHS requires a harmonized criteria for classifying substances and mixtures according to their health, environmental and physical hazards.

• Harmonized hazard communication elements, including requirements for labeling and safety data sheets

HAZCOM vs. GHS

Chemical Identification - HCS• The HCS excludes certain

hazardous materials covered by other regulatory statutes– Pesticides – FIFRA– Chemicals substances or

mixtures covered by TSCA– Food, food additive, color

additive, drug, cosmetic or medical / veterinary device covered by Federal Food, drug and Cosmetic Act or the Virus-Serum Toxin Act

Chemical Identification - GHS• The GHS covers all hazardous

chemicals• Target audience includes

consumers, workers, transport workers and emergency responders

• There are no complete exemptions from the scope of the GHS for any particular product or chemical type.

HAZCOM vs GHS

LABELING CHANGES

HAZCOM vs GHS

• Labeling System Changes– Hazardous materials are required to be labeled for

transport, storage and usage within a facility– GHS calls for a harmonization in the labeling process

to include standardized symbols and signal words– The changes are expected to be applied to the

workplace and consumer products– Transport application changes are not expected to

follow the GHS guidelines– The label format is being outlined so that information

is in the same location on all labels.

HAZCOM vs GHS

Information from the Globally Harmonized System (GHS) /Purple Book

HAZCOM vs GHS

Signal Words / Hazard Pictograms

HAZCOM vs GHS

• Signal Words– The words “Danger” and “Warning” are being

used as signal words to emphasize the hazard and indicate the relative level of the severity of the hazard as assigned by a GHS hazard class and category

• Danger – For more “severe” hazards

• Warning – For less “severe” hazards

HAZCOM vs GHS

• Hazard Pictograms– Standardized pictograms are intended to convey the hazard

through common pictures– The pictograms for non-transport will be red bordered with

white backgrounds and black symbols– For transport, the pictograms will follow the UN

Recommendations on the Transport of Dangerous Goods, Model Regulations and will have color as we currently recognize

– If the transport pictogram is present, there is not a requirement to place the GHS Hazard Pictogram

– Just like the current requirement for hazard communication on workplace bottles/containers, the GHS label should be affixed

HAZCOM vs GHS

• Examples of GHS Pictograms

Information from the Globally Harmonized System (GHS) /Purple Book

Hazcom vs. ghs• Examples of Transport Pictograms

Information from Globally Harmonized System (GHS) /Purple Book

HAZCOM vs GHS

Hazard & Precautionary Statements

HAZCOM vs GHS

• Hazard & Precautionary Statements– Hazard statements have been standardized

and given phrases that describe the hazard(s) as found in the hazard classification

– If there is more than one hazard, then the appropriate hazard statement should be included for all identified hazards

HAZCOM vs GHS

• Pictograms, Signal Words and Hazard Statements

HAZCOM vs GHS Safety Data Sheets

HAZCOM vs GHS

• Safety Data Sheets– Under GHS, (Material) Safety Data Sheets (SDS) will be in

a common format for all materials which require a SDS– The format is intended to provide an easier to read

document and allow for quicker identification of hazards and dangers of a product

– The SDS should contain 16 headings and is derived as a combination of document formats from

• ISO – International Organization of Standardization• EU – European Union• ANSI – American National Standards Institute

HAZCOM vs GHS

• Safety Data Sheets– The minimum recommended information includes:

• Section 1 – Identification of the substance or mixture and the supplier

– GHS Product Identifier– Recommended uses– Supplier details (address, phone number)– Emergency phone numbers

• Section 2 – Hazard identification– GHS classification of the substance/mixture– GHS label elements (precautionary statements, hazard symbols)– Other hazards not classified by GHS (ie dust explosion hazard)

HAZCOM vs GHS

• Safety Data Sheets– The minimum recommended information includes:

• Section 3 – Composition / Ingredients– Chemical Identity – common name, synonyms, CAS number,

impurities/stablizers, concentrations or concentration ranges

• Section 4 – First Aid– First aid measures based on the different routes of exposure,

most important symptoms/effects, indication of immediate medical attention if necessary

• Section 5 – Firefighting– Suitable / unsuitable extinguishing media– Special protective equipment and precautions for firefighters

HAZCOM vs GHS

• Safety Data Sheets– The minimum recommended information

includes:• Section 6 – Accidental Release

– Personal precautions, environmental precautions and containment / cleanup materials and methods

• Section 7 – Handling and Storage– Precautions for safe handling– Conditions for safe storage

• Section 8 - Exposure controls– Control parameters, engineering controls and individual

protective measures – PPE

HAZCOM vs GHS

• Safety Data Sheets– The minimum recommended information includes:

• Section 9 – Physical / Chemical Properties– Properties about the material (e.g. state, appearance, odor, pH,

flash point, vapor density, etc)

• Section 10 – Stability / Reactivity– Chemical stability, reaction possibilities, conditions to avoid,

incompatibilities, decomposition products

• Section 11 – Toxicological Information– Likely routes of exposure– Symptoms associated with physical, chemical and toxicological

characteristics– Numerical measures of toxicity

HAZCOM vs GHS

• Safety Data Sheets– The minimum recommended information includes:

• Section 12 – Ecological Information– Aquatic / Soil Toxicity– Persistence and degradability– Bioaccumulation potential

• Section 13 – Disposal– Recommended disposal methods

• Section 14 – Transportation– UN Number, Proper Shipping Name, Hazard Class, Packing Group– Marine Pollutant (Yes/No)– Special Precautions

HAZCOM vs GHS

• Safety Data Sheets– The minimum recommended information

includes:• Section 15 – Regulatory Information

– Regulatory bodies that govern the chemical / mixtures (e.g. SARA, TCSC, FIFRA)

• Section 16 – Other Information– Preparation and revisions on SDS should be in this section

HAZCOM vs GHS

• Safety Data Sheets– With uniform data fields and common

terminology, information can easily be found on the sheets

– Worker understanding of the dangers will also be easier to define

HAZCOM vs GHS

Terms & Definitions

HAZCOM vs GHS

• Terms / Definitions– Common terminology will require all systems (OSHA,

EPA, EU, DOT, Canadian, etc) to adopt some changes in order to meet the harmonized goal of the GHS

– Examples of changes / revisions on terminology for common reference

• Gas – substance / mixture which at 50oC has a vapor pressure greater than 300kPa

• Liquid – substance/mixture that is not a gas and has a melting point of 20oC or less at standard pressure

• Solid – substance/mixture that does not meet the definitions of a liquid or a gas

HAZCOM vs GHS

• Examples of changes in standards for consistency– Flammable / Combustible liquids

• For the purpose of classifying liquids, under the GHS system any liquid that has a flashpoint of not more than 93oC (200oF) is considered a flammable liquid

– Four categories will be used based on the flash point and boiling point of a liquid

» 1 = Flash point < 23oC (73.4oF) and initial boiling point < 35oC (95oF)

» 2 = Flash point < 23oC (73.4oF) and initial boiling point >35oC (95oF)

» 3 = Flash point > 23oC (73.4oF) and < 60oC (140oF)» 4 = Flash point > 60oC (140oF) and < 93oC (200oF) – Current

combustible liquid range

HAZCOM vs GHS

• Examples of changes in standards for consistency– Process Safety Management

• For consistency within the GHS program, OSHA is looking at modifications to the PSM program

– Clear differentiation between the process tanks and storage tanks

– Changes to the toxicity classifications under GHS will affect the PSM standards

HAZCOM vs GHS

• Training– Under the current hazard communication system,

employers are required to train employees on the hazard associated with products

– Right-to-Know stations must be provided– GHS does not change this requirement and

stresses the importance of training for employees– The GHS harmonization with labels / SDS

/terminology is intended to make training easier for all

HAZCOM vs GHS

• What can you do to prepare?– Final regulatory approval appears to be forth coming

with a several year implementation period– Companies can begin obtaining the warning labels

that are part of the GHS system now for training and understanding

– Implement usage of the new labels in a phased approach based on the current standards

– Conduct training sessions with workforce in short “coffee break” times that will introduce the new system

HAZCOM vs GHS

• What can you do to prepare and create harmony?– If you prepare MSDS sheets (current term)

• Begin referring to the document as a Safety Data Sheet (SDS)

• Re-format your SDS to match the GHS format• Provide training on the new format to employees

– For MSDS sheets you receive• Ask suppliers if they can provide in the new format

– Right-to-Know Stations• Update stations with new SDS and advise employees

HAZCOM vs GHS

• What can you do to prepare and create harmony?– Display posters / sheets showing the new

labeling in the workplace to begin familiarization by employees

– Show the correlation between current systems and the new system

– Provide information for employees to ask/answer questions

HAZCOM vs GHS • GHS Reference

– A Guide to The Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

http://www.osha.gov/dsg/hazcom/ghsguideoct05.pdf

HAZCOM vs GHS

• Questions?