NW HELP Group Meeting - August 14, 2013
Presented by Chris Antony, EH&SO IDRI, Seattle, Washington
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
1
©2013 NW HELP Group: Permission to use
granted provided attribution is shown
08/09/2013
2

Closed Course: Professional Drivers Only
◦ “Explanations create comprehension but plans create action”
◦ BUT – If I miss it, get it wrong, or don’t hit the goal – please say something

This presentation is distilled from a number of sources;
◦ An excellent 08/01/13 presentation by Denise Deeds, CIH, at
UW’s NW Center for Occupational Health and Safety
◦ Information from Pamela Edwards, IH, with WA L&I, DOSH
◦ UN Publication on GHS 5th revised edition
◦ Websites for OHSA, NIOSH, WISHA, CDC/NIH
◦ Very good SDS vs MSDS Presentation by staff at JK, Inc., Houston
◦ GHS Implementation Course, National Safety Council
◦ Additional resources listed under Toolkit
©2013 NW HELP Group: Permission to use granted provided attribution is shown 08/09/2013
3
Not Covering
 How to ‘assemble’ an SDS
 Non-Lab GHS implementation
 GHS impacts to other Regs
 DOT issues
 A bunch of other stuff
Covering
 UN GHS Development
 GHS Implementation in US
 Brief Recap of 1900.1200/1450
 WA State Implementation
 Detailed Review of GHS parts
◦ Labels
◦ Pictograms & Hazard revisions
◦ SDS sections




Suggested Action Plan
Ongoing Issues
Toolkit & Resources
Membership in WSACL
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
4



1989 - ILO Convention on Safety in the Use of Chemicals at Work
1992 - Rio “Earth Summit” established 6 program areas on sound
management of chemicals - including harmonization of classification and
labeling of chemicals
1994 - IOMC (Interorganization Programme for the Sound Management
of Chemicals) The Coordinating Group for the Harmonization of Chemical
Classification Systems led the effort. Technical Work:
◦ Physical Hazards - UN Experts on TDG
◦ Health/Environmental Hazards - OECD
◦ Hazard Communication – ILO


1994 - OHSA implements new HSC
UN Adopted Basic GHS components and published “Purple Book” in
December 2002,
◦ Rev 1: 2005, Rev 2: 2007, Rev 3: 2009, Rev 4: 2011
◦ Rev 5: 2013 [see toolkit]
GHS Development Overview
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
5




CPSC (Consumer Labeling) changes are under consideration/development
EPA (Pesticides) – 2004 White Paper, 10/06 stakeholder meetings, pursuing voluntary pilot
activities, working on interagency coordination. 4/9/12 issued PR Notice 2012-1 Guidance
on how to comply with OSHA and EPA re: SDS
DOT adopted changes to regulations to implement the GHS in the transport sector and
remain harmonized with the UN TDG – except DOT permits but does not require aquatic
toxicity classification: retains the current system
OSHA’s Approach maintains the basic requirements of the current standard
 Only change those provisions such as HazCom that need to be changed to adopt the GHS
 “Right to Know” becomes “Right to Understand”
 Maintain or enhance the level of protection provided by the HCS [thus 2012 rev] looking at
scope of chemicals, hazards, information availability and workplace requirements
 Allow exemptions to GHS labeling requirement [list in toolkit] including Haz Waste, Bio
hazards (infectious only), Radiation (ionizing and non-ionizing), Consumer products only if
used in consumer manner (e.g. Bleach)
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
6
OHSA - Hazard Communication Standard 2012
[Verbatim text]


(a) Purpose.
(a)(1) The purpose of this section is to ensure that
the hazards of all chemicals produced or imported
are classified, and that information concerning the
classified hazards is transmitted to employers and
employees. The requirements of this section are
intended to be consistent with the provisions of the
United Nations Globally Harmonized System of
Classification and Labeling of Chemicals (GHS),
Revision 3. The transmittal of information is to be
accomplished by means of comprehensive hazard
communication programs, which are to include
container labeling and other forms of warning, safety
data sheets and employee training.
OHSA - Hazard Communication
Standard 2012 [CTTC text]
1. Ensure chemical hazards are classified
2. Transmit this info to employees via
◦ Container labels – Pictograms!
◦ Safety Data Sheets
◦ Training
3. All info to be consistent with GHS
Lab specific Regs are 1910.1450
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
7
Pre-GHS
“Right to Know”
Post-GHS
‘Right to Understand”
Hazard Determination
Hazard Classification
A Chemical Hygiene Officer
A Chemical Hygiene Officer who is GHS Trained
A Written Chemical Hygiene Plan
NPFA hazards
MSDS knowledge
A Chemical Hygiene Plan with GHS items added
Understanding Pictograms/new hazards
Understanding how to read an SDS
Document Training
Document GHS Training
Label Chemicals in the Lab
Used the Manufacturers’
Label Chemicals: Decision on showing both GHS &
Non-GHS
Retain and provide MSDS access
Retain MSDS, Replace with SDS as received,
provide access
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
8

Compliance Dates Different

◦ Employers train on GHS labels & SDS
 Complete by JUNE 1, 2014 vs 12/1/13
◦ APRIL 15, 2013


New WAC Chapter
◦ Update is 296-901-140
◦ Essentially matches the
Federal version
◦ WAC 296-839 (MSDS)
not updated
◦ Distributors ship only GHS labels
 By DECEMBER 1, 2015
◦ Employers update HazCom
 By JUNE 1, 2016
Employer HazCom
◦ WAC 296-800-170
◦ Manufacturers comply with labeling
 Complete by JUNE 1, 2015
WA Rulemaking effective

GHS changes some 25
other WACs
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
9
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
10
Labels
Goal: Understand the Six Parts
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
11
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
12
New GHS Labels draw all statements from existing text, listed by
hazard class – this table is an example of the process
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
13
Our challenge is well illustrated by this table
 1 is the new 4
 4 is the new 1
 “Pink is the new black”
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
14
Pictograms
Goal: Understand the Change to
Hazard Classification Represented
by Each Pictogram
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
15
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
16
Hazard Categories within a Classification are determined by Data
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
17
Full definitions of each of the sub categories are in Appendix A
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
18
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
19
Exploding Bomb says it all!
Flame
 This is a complex set of hazards that includes high-use
materials for labs
 Gases, Aerosols, Liquids, and Solids
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
20
Oxidizing materials
 Gas = O2 and O3
 Liquids = Nitric Acid, Chromic acid, Sodium Hypochlorite
 Solids = Chromate, Potassium Permanganate
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
21
Will be used in by two different Risk Categories
 Chemical/PhysicalRisk = e.g. Corrosive Metals
 Health Risk = e.g. Eye Damage
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
22
Remember: Category 4 = least hazardous condition
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
23
Environment Pictogram: “Dead Tree Dead Fish”
 No current standard for non-aquatic species e.g. Bees
 If it is a category 3 or 4 Environment = no symbol no signal word
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
24
Safety Data Sheets
Goal: Understand the Section
changes and where to look for
needed data
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
25
SAFETY DATA SHEET SECTIONS
Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-Aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical properties
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information
Section 13. Disposal considerations
Section 14. Transport information
Section 15. Regulatory information
Section 16. Other information, including date of preparation or last revision
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
26
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
27
©2013 NW HELP Group: Permission to use
granted provided attribution is shown
08/09/2013
28
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
29
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
30
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
31

A revised 2012 OHSA Hazard Communication Standard
incorporates a UN based Global Harmonization System for
chemical labeling and handling – WA State Adopts

New GHS Labels have 6 parts

Pictograms represent 9 hazard classifications distributed among
three hazard groups: one used in two different groups

A 16 section Safety Data Sheet replaces the MSDS
©2013 NW HELP Group: Permission to use
granted provided attribution is shown
08/09/2013
32

Lab Chem db’s need “agreed to” identifier: IDRI uses CAS
◦ No standard identifer agreed-to at this point – what about mixtures?

Further GHS impacts to Lab operations may occur as WA’s
State/Local Agencies adjust to GHS
◦ Adjustment of APP, BECP, or other regs.
◦ Fire Dept Regs - Future impact on SFD HMIS classification (2009 fire code)

SDS Conversion by Chemical vendors has a long way to go
◦ Informal survey of IDRI suppliers shows a broad range of progress

UN Two YR GHS Update process will cause additional changes
◦ e.g. Combustible dusts [un-defined] now specifically addressed – change?
◦ Status of Environmental hazards and implementation
©2013 NW HELP Group: Permission to use
granted provided attribution is shown
08/09/2013
33

By Sept 2
◦ “Dig out” your written Hazard Communication Standard (whether it’s 1900.1200
or 1450) and review it – then decide if you will hold GHS training in 2013 or 2014
THEN set the date! (IDRI will be Training 10/22-26/13)
◦ You can’t train on subjects that you don’t understand so honestly spend a couple
of hours reviewing the hazard classification changes – you’ll get everything else
◦ Determine how you will handle incoming new SDS’s within current system &
retain copies of ‘old’ MSDS.

By Sept 30
◦ CRITICAL – don’t wait to create GHS training materials even if you elect to do
the training in first half of 2014 – You’ll run out of time! This training should be
KSS = Labels/Picto & Haz Class/SDS.

By Nov 30
◦ Identify other GHS impacts to your organization [i.e. writing of in-house SDS’s]
◦ Think about being on a Beach in San Diego
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
34
1. A Detailed summary recap of Hazard Classifications by Pictogram
 Haz Class Summary Deeds.pdf
 Appendix A Detailed Hazard Classifications.pdf
2. Direct comparison of OSHA’s HCS 1994 v 2012
 https://www.osha.gov/dsg/hazcom/side-by-side.html
3. UN Purple Book 5th Edition in pdf form
4. Comparison of SDS new Format vs MSDS
 MSDSvsSDS_McKelvey_Aug2012
5. Detailed Guidance for Writing an SDS
 GHS Presentation UW 080113 [Work by Denese Deeds]
©2013 NW HELP Group: Permission to use
granted provided attribution is shown
08/09/2013
35
Don’t be a Member of
WSACL
Washington State Amateur
Crastinator League
Turning Pro Right After This
GHS Presentation!
©2013 NW HELP Group: Permission to use granted provided attribution is shown
08/09/2013
36