Hazard Communication and
the Global Harmonized System
Joann Natarajan
OSHA
Austin Area Office
What Has Changed?
• Issued March 26, 2012
• Affects 29 CFR 1910.1200
• Affects other regulations: Welding
Flammables, and substance specific
standards
• Label and hazard warnings were
harmonized in the substance specific
regulations
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GHS
• The major changes to the HCS:
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Hazard Classification
Labels
Safety Data Sheets
Information and Training
• Will affect nearly 40 million workers and 5 million
workplaces
GHS
• It is estimated that
implementing the GHS will
prevent 43 fatalities and 585
injuries and illnesses annually
• The DOT has already
modified their requirements
for classification and labeling
to be consistent with UN
transport requirements and
the GHS
GHS Hazard Classification
• The list of chemicals presenting a ‘Health’
hazard was deleted from the current HCS and
the proposed HCS has identified a new listing
• A ‘Health Hazard’ means a chemical which is
classified as posing one of the following
hazardous effects:
GHS Hazard Classification
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Acute Toxicity (any route of exposure)
Skin Corrosion or Irritation
Serious Eye Damage or Eye Irritation
Respiratory or Skin Sensitization
Germ Cell Mutagenicity
Carcinogenicity
Reproductive Toxicity
Specific Target Organ Toxicity (single or repeated
exposure)
– Aspiration Hazard
GHS Hazard Classification
• The list of chemicals presenting a ‘Physical’
hazard was deleted from the current HCS and
the proposed HCS has identified a new listing
• A ‘Physical Hazard’ means a chemical that is
classified as posing one of the following
hazardous effects:
GHS Hazard Classification
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Explosive
Flammable (gases, aerosols, liquids, or solids)
Oxidizer (liquid, solid, or gas)
Self-Reactive
Pyrophoric (liquid or solid)
Self-Heating
Organic Peroxide
Corrosive To Metal
Gas Under Pressure
Contact With Water Emits Flammable Gas
GHS Hazard Classification
• The HCS does not address environmental
hazards and OSHA does not have jurisdiction
over that. There are environmental hazard
classifications:
– Hazardous to the Aquatic Environment
• Acute Aquatic Toxicity
• Chronic Aquatic Toxicity
– Bioaccumulation Potential
– Rapid Degradability
OSHA Hazard Classification
• In OSHA’s rule there is a hazard category called
“Hazards not otherwise classified” which is not in
the UN GHS system
– … a substance that has an identified hazard,
but does not meet classification criteria for
physical or health hazard under GHS
– These substances are covered by the current
hazard communication law---so OSHA did not
want GHS to result in a less protective law
– OSHA added pyrophorics, combustible dust,
and asphyxiant s to the definition of “hazardous
chemical”
HNOC
• “Hazards not otherwise classified” will not
be required to be labeled
• Hazards will be disclosed on the SDS
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Carcinogens & Trade secrets
• Mixture is considered to be carcinogenic if
it contains .1% by volume criteria (unless
the mixture has health effects at less than
.1% carcinogen)
• Trade secret information is limited to the
names of chemicals and their
concentrations in mixtures.
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GHS Labels
• Three standardized GHS label elements:
– Symbols (Hazard Pictograms) that convey health,
physical, and environmental hazard information
assigned to a GHS hazard class and category
– Signal Words “Danger” or “Warning” used to
emphasize hazards and relative level of severity
of the hazard and assigned to a GHS hazard
class and category
– Hazard Statements which are standard phrases
assigned to a hazard class and category that
describe the nature of the hazard
GHS Labels
• Key Elements
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Product Identifier
Supplier Identifier
Chemical Identity
Hazard Pictograms*
Signal Words*
Hazard Statements*
Precautionary
Information
* Standardized
GHS Labels
Red
border
GHS
-----Black
border
Transport
GHS Labels
Hazard Classes may have ‘Categories’
GHS Labels vs. DOT Labels
• Outer shipping container – DOT compliant
• Inner container – GHS
• If there is only one container (ex. a 55 gal
drum), Appendix C lists which hazard
information has precedence on the label.
• A container will not have dual DOT and
OSHA labels to prevent confusion.
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NFPA and HMIS Labeling
Systems
• While alternatives are permitted for
workplace containers, the information
supplied must be consistent with the
revised law.
• Hazard classifications must be revised as
necessary to conform with the final rule,
and the other information provided must
be revised accordingly to ensure the
appropriate message is conveyed.
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Safety Data Sheets (SDS)
• The OSHA ‘Material Safety Data Sheet’ (MSDS)
will be called a ‘Safety Data Sheet’ (SDS)
• The MSDS has 8 non-mandatory sections
• The SDS will have 12 mandatory and 4 nonmandatory sections and is essentially the ANSI
Z400.1-2004 format
– Sections 12-15 are not mandatory and cover
Ecological, Disposal, Transport, and Regulatory
information
Safety Data Sheets (SDS)
Approach to Other Standards
• Many other OSHA standards contain criteria related
to defining hazards, as well as other provisions that
rely on those criteria
• OSHA undertook a comprehensive review of its
rules to identify what needed to be changed
• OSHA maintained the scope of existing standards
Health Standards
Asbestos (1910.1001;
1926.1101; 1915.1001)
13 Carcinogens (1910.1003)
Vinyl Chloride (1910.1017)
Inorganic Arsenic (1910.1018)
Lead (1910.1025; 1926.62)
Chromium (VI) (1910.1026;
1926.1126; 1915.1026)
Cadmium (1910.1027;
1926.1127)
Benzene (1910.1028)
Coke Oven Emissions
(1910.1029)
Cotton Dust (1910.1043)
1,2-dibromo-3-chloropropane
(1910.1044)
Acrylonitrile (1910.1045)
Ethylene Oxide (1910.1047)
Formaldehyde (1910.1048)
Methylenedianiline (1910.1050;
1926.60)
1,3-Butadiene (1910.1051)
Methylene Chloride (1910.1052)
Occupational exposure to
hazardous chemicals in
laboratories (1910.1450)
Safety Standards
Flammable Liquids (1910.106; 1926.52)
Spray finishing using flammable and combustible materials (1910.107)
Process safety management of highly hazardous chemicals (1910.119;
1926.64)
Hazardous waste operations and emergency response (1910.120;
1926.65)
Dipping and coating operations: Coverage and definitions (1910.123)
General requirements for dipping and coating operations (1910.124)
Additional requirements for dipping and coating operations that use
flammable liquids or liquids with flashpoints greater than 199.4 oF
(93 oC). (1910.125)
Welding, Cutting, and Brazing (1910.252): Labels on welding rods
Flammable Liquid Classification
GHS - OSHA Crosswalk
GHS
Flammable and Combustible Liquids Standard
(29 CFR 1910.106)
Flashpoint ºC (°F)
Boiling
Point
ºC (°F)
Flammable 1
< 23 (73.4)
≤ 35 (95)
Flammable Class IA
< 22.8 (73)
< 37.8
(100)
Flammable 2
< 23 (73.4)
> 35 (95)
Flammable Class IB
< 22.8 (73)
≥ 37.8
(100)
Flammable 3
≥ 23 (73.4) and
≤ 60 (140)
Flammable Class IC
Combustible Class
II
≥ 22.8 (73) and <
37.8 (100)
≥ 37.8 (100) and <
60 (140)
Flammable 4
> 60 (140) and
≤93 (199.4)
Combustible Class IIIA
≥ 60 (140) and
<93.3 (200)
Combustible Class IIIB
≥ 93.3 (200)
Category
None
Class
Flashpoint ºC (°F)
** Not covered by §1910.1200 or §1910.106 however interpretation letter indicates these are covered by §1910.107
Boiling Point
ºC (°F)
Spray Finishing
• There is no flash point cut off in 1910.107,
so to be consistent with GHS, OSHA
refers to liquids with flashpoints above
199.4 degrees F The term combustible
liquids will no longer be used.
•
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Flammables in Construction
• Temperature cut off for 1910 is 100
degree F
• In construction, temperature cut off is 140
degrees F
• Changed the definition of flammable
category 3 to have flashpoints between 74
and 140 degrees F, so coverage is
unchanged in construction.
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In House Labeling Systems
1910.1200(f)(6)(ii)
• NFPA & HMIS: Label must contain info
specified in Product identifier and words,
pictures, symbols, or combination which
provide at least general information
• Label must be in English, additional
languages may be added, but are not
required
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GHS Information and Training
• Two years after the Final Rule workers must be
trained on the new labels and Safety Data
Sheets - December 1, 2013
• Manufacturers have 3 months to issue new
SDS’s if info changes
• Six months to revise new labels when significant
information about a chemical is discovered
(j) Effective Dates
Requirement(s)
Who
December 1, 2013
Train employees on the new label
elements and safety data sheet
(SDS) format.
Employers
June 1, 2015*
December 1, 2015
Compliance with all modified
provisions of this final rule, except:
The Distributor may ship containers
labeled under the HCS 1994 by a
manufacturer or importer until
December 1, 2015.
Chemical manufacturers, importers,
distributors and employers
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
Effective Completion Date
HCS Appendices
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Appendix A: Health Hazard Criteria
Appendix B: Physical Hazard Criteria
Appendix C: Allocation of Label Elements
Appendix D: Safety Data Sheets
Appendix E: Trade Secret (unchanged)
Appendix F: Guidance for Hazard Classification
Regarding Carcinogenicity
GHS Changes in the Future
• The GHS is updated as needed to reflect new
technology and scientific developments, or
provide explanatory text. Changes to the HCS is
anticipated through:
– Technical Updates for minor terminology changes
– Direct Final Rules for text clarification
– Notice and Comment Rulemaking for more
substantive or controversial updates such as
additional or changes in health or safety hazard
classes or categories
Resources
• Many elements of the
GHS are going to be
found in the ‘GHS
Purple Book’
• You can purchase
from the UN
bookstore, or
download it for free,
link on OSHA website
Resources
• On the OSHA website
under ‘Safety and
Health Topics’ there
is a Hazard
Communication
webpage with many
resources and
documents including
a link to a GHS page
Resources
• The GHS webpage
has lots of documents
including side by side
comparisons of the
HCS and the new
proposed HCS
Resources
• OSHA published ‘A
Guide to The Globally
Harmonized System
of Classification and
Labeling of Chemicals
(GHS)
• It can be downloaded
from the OSHA
website
Updated Webpages
HCS 2012 Webpage:
http://www.osha.gov/dsg/hazcom/index.html
Safety & Health Topics Webpage:
http://www.osha.gov/dsg/hazcom/index2.html
Questions?
• Natarajan.joann@dol.gov
• 512-374-0271 x 232