New Chemical Hazard
Communication Standard
Globally Harmonized System of
Classification and Labeling of
Chemicals, WAC 296-901-140
Overview of GHS and
changes to the standard
What is the GHS?
 Harmonized criteria for classifying substances
and mixtures according to their health,
environmental and physical hazards.
 Harmonized hazard communication system
including requirements for labeling and safety
data sheets (SDS).
 Target audience - workers, employers,
consumers, transport workers, emergency
responders.
http://bit.ly/LRVdsf
Agencies Involved with the GHS
Federal
Washington State
DOT
WSDOT
OSHA
L&I / DOSH
EPA
DOE & WSDA
CPSC
Dark green: Countries/regions that have already implemented GHS.
Light green: Countries/regions where GHS is voluntary.
Yellow: Countries/regions that are in the process of implementing GHS.
Blue: Countries/regions where GHS is not implemented or not available.
OSHA’s “HazCom 2012” Standard
 Published March 26, 2012
 Conforms to the GHS, Rev. 3
 Changes to:
– Hazard classification
– Label content
– Safety Data Sheet content (mandatory 16 section
SDS, % required)
Stay tuned . . .
 The GHS is updated on a two year cycle.
 Recent updates have mostly been text
clarifications.
 Future updates of the Chemical Haz Com
standard may be necessary.
WISHA’s new GHS-based
Hazard Communication Standard
Effective April 15, 2013
Substantially identical to OSHA’s standard
Phase-in schedule:
– During the transition period, there is the option to comply with
the applicable requirements in the existing rules, or the
requirements in the new rule, or both.
– June 1, 2014: ERs train EEs on Safety Data Sheet (SDS)
format and new label elements.
– June 1, 2015: Manufacturers & importers comply with new
SDS and label requirements.
– Dec. 1, 2015: Distributors not to ship unless container has
GHS label.
Substantially identical to OSHA’s standard
Phase-in schedule, cont.:
– June 1, 2016: ERs update labels, EE hazard
training, and written Haz Com programs.
– Upon completion of the transition period, the
existing standard (296-800-170) will be repealed.
Exemptions
 All the current exemptions from the rule, and
exemptions from labeling, still apply.
 One new exemption from the rule:
– “Nuisance particulates where the chemical
manufacturer or importer can establish that they do
not pose any physical or health hazard covered
under this section.”
Major Changes
 Labels & SDS
– No longer performance-based.
– Each hazard class and category has specified
hazard statement(s), signal word, pictogram(s),
and precautionary statement(s) in mandatory
Appendix C.
Those elements must appear on the label and
SDS.
Major Changes
 Hazard determination
– Now titled “hazard classification”
– Detailed data-based criteria
• Health hazard criteria in mandatory Appendix A and
non-mandatory Appendix F
• Physical hazard criteria in mandatory Appendix B
– Specified; no longer performance-based
Classification of chemical hazards
 Hazard class: the nature of the physical or
health hazards, e.g., flammable solid,
carcinogen, oral acute toxicity.
 Hazard category: division by degree or type
of hazard within each hazard class.
Hazard Class
Hazard Category
(health hazard criteria, Appendix A)
Acute toxicity
1
2
3
4
Skin corrosion/irritation
1A
1B
1C
2
Serious eye damage/irritation
1
2A
2B
Respiratory or skin sensitizers
1A
1B
Germ cell mutagenicity
1A
1B
2
Carcinogenicity
1A
1B
2
Reproductive toxicity
1A
1B
2
Specific target organ toxicity - single
exposure
Specific target organ toxicity - repeated
exposure
Aspiration
1
2
3
1
2
1
lactation
Hazard Class
Hazard Category (physical hazard criteria, Appendix B)
Explosive
Flammable gases
Flammable aerosols
Oxidizing gases
Gases under pressure
Unstable
1
1
1
Compressed
Div 1.1
2
2
Div 1.2
Div 1.3
Liquefied
Dissolved
Flammable liquids
Flammable solids
Self-reactive
Pyrophoric liquids
Pyrophoric solids
Self-heating
Emits flammable gas when
in contact with water
Oxidizing liquids
Oxidizing solids
Organic peroxides
Corrosive to metals
1
1
A
1
1
1
1
2
2
B
Refrigerated
liquefied
3
C
D
E
F
G
2
2
3
1
1
A
1
2
2
B
3
3
C
D
E
F
G
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Label Requirements
1. Find the hazard class
From Appendix B:
2. Find the hazard category
From Appendix B:
3. Find the required label elements
From Appendix C:
Label pictograms
Exploding Bomb Symbol
 Unstable Explosives
 Explosives (Divisions 1.1-1.4)
 Self-reactives (Type A and
Type B with Flame)
 Organic Peroxides (Type A
and Type B with Flame)
Flame Symbol
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Flammable Gases
Flammable Aerosols
Flammable Liquids (Categories 1-3)
Flammable Solids
Self-Reactives (Type B with bomb, Types
C-F)
Pyrophoric liquids and solids
Self-heating substances
Substances which in contact with water
emit flammable gases
Organic Peroxides (Type B with bomb,
Types C-F)
Flame over Circle Symbol
 Oxidizing Gases
 Oxidizing Liquids
 Oxidizing Solids
Gas Cylinder Symbol
 Compressed Gas
 Liquefied Gas
 Refrigerated Liquefied Gas
 Dissolved Gas
Corrosion Symbol
 Corrosive to Metals (steel or
aluminum >6.25 mm/year at
55C)
 Skin corrosion/ irritation –
Category 1 (A, B and C)
 Serious eye damage/
irritation – Category 1
Skull and Crossbones Symbol
 Acute Toxicity –
Categories 1-3 (oral,
inhalation or dermal
routes)
Exclamation Mark Symbol
 Acute Toxicity – Category 4 (oral, inhalation
or dermal routes)
 Skin Irritation/ Corrosion – Category 2
 Serious Eye damage/ irritation – Category
2A
 Skin Sensitizer
 Specific target organ toxicity (single
exposure) – Category 3 (respiratory tract
irritation, narcotic effects)
 Hazardous to the Ozone Layer
Health Hazard Symbol
 Respiratory Sensitizer
 Germ Cell Mutagenicity
 Carcinogenicity
 Toxic to Reproduction
 Specific target organ toxicity (single
exposure) – Categories 1-2
 Specific target organ toxicity
(repeated exposure) – Categories 1-2
 Aspiration Hazard
Environment Symbol*
 Acute hazards to the aquatic
environment – Category 1
(Categories 2 and 3 use no
symbol or signal word)
 Chronic hazards to the aquatic
environment – Categories 1 and 2
(Categories 3 and 4 use no
symbol or signal word)
*Part of GHS, but not required by WISHA or OSHA standards.
Hazard statements
 Hazard statement is specified for each level of
hazard (category) within each hazard class
(See Appendix C)
– Example: Flammable liquids
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Category 1: Extremely flammable liquid and vapour
Category 2: Highly flammable liquid and vapour
Category 3: Flammable liquid and vapour
Category 4: Combustible liquid
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Hazard statements
 The text of all applicable hazard statements
shall appear on the label.
 Hazard statements may be combined where
appropriate to reduce the information on the
label and improve readability, as long as all of
the hazards are conveyed as required.
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Multiple hazards
 The pictogram and signal word used must
reflect the most severe hazard category; and
all relevant hazard statements must be used.
– If skull and crossbones, no exclamation point for
acute toxicity
– If corrosive, no exclamation point for eye/skin
irritation
– If health hazard for respiratory sensitization, no
exclamation point for skin sensitization or eye/skin
irritation
Precautionary statements
"Precautionary statement" means a phrase that
describes recommended measures that should
be taken to minimize or prevent adverse effects
resulting from exposure to a hazardous
chemical, or improper storage or handling.
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Precautionary statements
 There are 4 types of precautionary statements
–
–
–
–
Prevention
Response
Storage
Disposal
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Precautionary statements
 May be combined or consolidated to save label space
and improve readability.
 Where a chemical has multiple hazards and the
precautionary statements are similar, the most
stringent shall be included on the label.
 An order of precedence may be imposed.
 If the chemical manufacturer, importer, or responsible
party can demonstrate that a precautionary statement
is inappropriate to a specific substance, it may be
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omitted from the label.
Supplementary hazard information
 Only allowed if it provides further detail and does not
contradict or cast doubt on the validity of the
standardized hazard information.
 Placement shall not impede identification of
information required by the Standard.
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Label arrangement
 Label elements must be located together on the label,
tag or mark.
 Must not conflict with DOT regulations.
 Pictograms must have red border.
 Red frame must be wide enough to be clearly visible.
 Blank red diamonds are not permitted.
 Where a DOT label appears on a shipped container,
the same OSHA pictogram shall not appear.
 Labels must be in English (other languages also
permitted).
1. Product identifier
2. Signal word
3. Pictogram(s)
4. Hazard statement(s)
5. Precautionary statement(s)
6. Contact info for responsible party
Potential for confusion
 In NFPA 704 and HMIS, “4” = severe hazard
 In GHS, “4” = low hazard
HMIS/NFPA
GHS
Index
1
2
3
4
Category Hazard
1
highest
2
high
3
medium
4
low
Hazard
slight
moderate
serious
severe
 From the preamble to OSHA’s new standard:
“Neither the proposal nor final rule prohibits the use of
NFPA or HMIS rating systems.”
– Federal Register, 77(58), Monday, March 26, 2012, p. 17758
Potential for confusion
 May confuse employers who need to look up
hazard categories.
 Most employees won’t notice unless it’s
covered in their training, because hazard
categories don’t appear on labels or SDSs
(only used to determine required label info)
Potential for confusion
Safety Data Sheets
 16-section format now required, similar to the current
ANSI format.
 Order of the sections is specified.
 Specific required information for each section is in
mandatory Appendix D.
 Environmental provisions are included to be GHScompliant; DOSH will not enforce (sections 12-15).
Safety Data Sheets
 Must be in English (additional languages OK)
 If there’s no relevant information for a section, it must
be marked to indicate no data
 Preparer must assure information accurately reflects
the scientific evidence used in making the hazard
classification
 Preparer must update within 3 months of significant
new information. If not currently produced, then before
shipped again or introduced into the workplace.
SDS distribution
 Provide with initial shipment, and with first
shipment after update.
 Either before or with the shipment, on request.
 Retail and wholesale distributors shall post a sign
or inform employers that SDSs are available.
New SDS elements
 Standardized pictograms, hazard statements,
signal words, and precautionary statements
 Exact percentages of ingredients are required
in most cases; some may still give ranges:
– When there is a trade secret claim.
– When a product varies batch-to-batch.
– For a group of substantially similar mixtures with
similar chemical composition.
SDS required sections
1. Identification
2. Hazard(s) identification
3. Composition/information on
ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling & storage
8. Exposure control/personal
protection
9. Physical & chemical properties
10. Stability & reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information
Section 1 - Identification
 Product identifier used on the label or other
means of identification;
 Name, address, and telephone number of the
chemical manufacturer, importer, or other
responsible party;
 Emergency phone number
Section 2 - Hazard(s) identification
 Classification of the chemical
 Signal word, hazard statement(s), symbol(s)
and precautionary statement(s).
 Hazard symbols may be provided as graphical
reproductions in black and white or the name
of the symbol, e.g., flame, skull and
crossbones, etc.
Section 3 - Composition / Ingredients
For substances:
 Chemical name
 Common name and synonyms
 CAS number and other unique identifiers
 Impurities and stabilizing additives which are
classified and contribute to the classification
of the substance.
Section 3 - Composition / Ingredients
For mixtures:
Info required for substances, plus:
 Chemical name and concentration (exact or
range) of all ingredients which are classified
as health hazards and
– are present above their hazard class cutoff/concentration limits; or
– present a health risk below the hazard class cutoff/concentration limits.
Section 4 - First-aid measures
 Description of necessary measures,
subdivided according to the different routes of
exposure, i.e., inhalation, skin and eye
contact, and ingestion.
 Most important symptoms/effects, acute and
delayed.
 Indication of immediate medical attention and
special treatment needed, if necessary.
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Section 5 - Fire-fighting measures
 Suitable (and unsuitable) extinguishing media.
 Specific hazards arising from the chemical
(e.g., nature of any hazardous combustion
products).
 Special protective equipment and precautions
for fire-fighters.
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Section 6 - Accidental release measures
 Personal precautions, protective equipment,
and emergency procedures.
 Methods and materials for containment and
cleaning up.
Section 7 - Handling and storage
 Precautions for safe handling.
 Conditions for safe storage, including any
incompatibilities.
Section 8 - Exposure Controls/Personal
Protection
 Permissible exposure limit (PEL), Threshold
Limit Value (TLV), and any other exposure
limit used or recommended by the chemical
manufacturer, importer, or employer preparing
the safety data sheet, where available.
 Appropriate engineering controls.
 Individual protection measures, such as
personal protective equipment.
Section 9 - Physical and Chemical Properties
 Appearance (physical state,
color, etc.)
 Odor
 Odor threshold
 pH
 Melting point/freezing point
 Initial boiling point and
boiling range
 Flash point
 Evaporation rate
 Flammability (solid, gas)
 Upper/lower flammability
or explosive limits
 Vapor pressure
 Vapor density
 Relative density
 Solubility(ies)
 Partition coefficient:
n-octanol/water
 Auto-ignition temperature
 Decomposition temp.
 Viscosity
Section 10 Stability and Reactivity
 Reactivity
 Chemical stability
 Possibility of hazardous reactions
 Conditions to avoid (e.g., static discharge,
shock, or vibration)
 Incompatible materials
 Hazardous decomposition products
Section 11 - Toxicological Information
Description of health effects and the available
data used to identify those effects, including:
 Information on the likely routes of exposure
(inhalation, ingestion, skin and eye contact)
 Symptoms related to the physical, chemical and
toxicological characteristics
 Delayed and immediate effects and also chronic
effects from short- and long-term exposure
Section 12 - Ecological Information
Non-mandatory
 Ecotoxicity (aquatic and terrestrial, where
available)
 Persistence and degradability
 Bioaccumulative potential
 Mobility in soil
 Other adverse effects (such as hazardous to
the ozone layer).
Section 13 - Disposal Considerations
Non-Mandatory
 Description of waste residues and information
on their safe handling and methods of
disposal, including the disposal of any
contaminated packaging.
Section 14 Transport Information
Non-Mandatory
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UN number
UN proper shipping name
Transport hazard class(es)
Packing group, if applicable
Environmental hazards (e.g., Marine pollutant)
Special precautions which a user needs to be aware
of in connection with transport or conveyance either
within or outside their premises.
Section 15 Regulatory Information
Non-Mandatory
 Safety, health and environmental regulations
specific for the product in question.
Section 16 - Other Information
 The date of preparation of the SDS or the last
change
 References
Compliance assistance
Effective dates for employers
 During the transition period, option to comply
with the requirements in the existing rules, or
the requirements in the new rule, or both.
 June 1, 2014: Train EEs on Safety Data
Sheet (SDS) format and new label elements.
 June 1, 2016: Update labels, train EEs on
new hazards, and update written Chemical
Haz Com programs.
Help available from DOSH
Help available from DOSH
Help available from DOSH
Help available from DOSH
Additional help from DOSH
 Consultation Services
– Customized training assistance for employers on
request.
– Workshops being developed.
 Education & Outreach
– Online training modules being developed by
Ernesto Carcamo.
GHS-related changes to
other standards
GHS requires changes in 25 other standards
1. Wording of hazard signs and labels.
2. Definitions of flammable and combustible
materials in multiple standards.
Affects virtually all standards addressing
chemical hazards (including PSM, laboratories,
spray finishing, dipping, coating, welding,
hazardous waste, emergency response, etc.)
GHS requires changes in 25 other standards
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Welding, Cutting, & Brazing
Flammable & Combustible Liquids
Spray finishing
Shipbuilding, -Repairing & -Breaking
Hexavalent Chromium
Cotton Dust
Coke Ovens
Asbestos, Tremolite, Anthophyllite, &
Actinolite
Carcinogens
Vinyl Chloride
Acrylonitrile
1,2-Dibromo-3-chloropropane
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Cadmium
Butadiene
Methylene chloride
Lead
Methylenedianiline (MDA)
Hazardous Chemicals In Laboratories
Process Safety Management
Dipping & Coating Operations
Hazardous Waste Operations
Arsenic
Benzene
Ethylene Oxide
Formaldehyde
Other resources
www.osha.gov/dsg/hazcom
www.schc.org
DOSH Specialist on GHS:
Pam Edwards, Industrial Hygienist, MES
DOSH Technical Services, Tumwater
Pamela.Edwards@lni.wa.gov
(360) 902-6457