LABELING REQUIREMENTS UNDER THE NEW
OSHA GLOBAL HARMONIZATION STANDARD
Rob Harrington, Ph.D.
October 8, 2014
OVERVIEW
 OSHA issued the final rule to revise 29 CFR 1910.1200 (Hazard
Communication Standard) that appeared in the Federal Register
on 3/26/12.
 The goal was to integrate components of the UN Global
Harmonization Standard (GHS) into the OSHA HazCom
standard.
 The rule modifies MSDS (Now SDS) requirements, labeling,
classifications, and requires retraining of all employees.
OVERVIEW
 Hazard classification: Provides specific criteria for classification
of health and physical hazards od substances as well as
mixtures.
 Labels: Chemical manufacturers and importers will be required
to provide a label that includes a harmonized signal word,
pictogram, and hazard statement for each hazard class and
category. Precautionary statements must also be provided.
 Safety Data Sheets: SDS will now be required to have a
specified 16-section format.
WHY DEVELOP A GLOBALLY HARMONIZED
STANDARD?
 Companies around the world are major importers/exporters of
chemicals
 Missing, contradictory or incomplete information on chemicals
may lead to reduced protections for workers and public.
 Large number of varying requirements around the world create
confusion, shipping issues and potential barriers to trade
 A harmonized and consistent approach has benefits both in
terms of protection and trade.
GHS PROJECT: INTERNATIONAL MANDATE
 The goal of establishing a globally harmonized system for hazard
communication was established in 1992 at the UN Conference on the
Environment and Development - “Rio Earth Summit”.
 The Mandate: “A globally harmonized hazard classification and
compatible labelling system, including national safety data sheets
and easily understandable symbols, should be available, if feasible,
by the year 2000.”
U.N. PURPLE BOOK – THE BASIS FOR GHS
OSHA FINAL RULE GHS IMPLEMENTATION
TIMELINE
 12/1/13: All employees must be trained on new label elements
and SDS format (better be done at this point!)
 6/1/15: Manufacturers and distributors must comply with all
modified provisions [labels, SDS] except that distributors have
until 12/1/15 to provide revised labels for all products shipped.
 6/1/16: OSHA enforcement starts: Employers must update all
labels and HazCom programs, provide additional training for
workers on newly identified physical or health hazards
 During transition period, employers can comply with old or new
standard as far as labels and SDSs.
BASIC ELEMENTS OF GHS
 Classification Criteria - each substance /mixture needs to be
classified:
 Health and environmental hazards
 Physical hazards
 Hazard Communication - apply the results of the classification
process to:
 Labels
 Safety Data Sheets
CLASSIFICATION
 "Classification" means to:
 identify the relevant data regarding the hazards of a chemical
 review data to ascertain the hazards associated with the
chemical
 decide whether the chemical will be classified as hazardous
according to the definition of hazardous chemical
 Hazard classification is a self-classification process –
manufactures and importers must classify each chemical/mixture,
determine the appropriate hazard class and category based on
the evaluation of full range of available data/evidence
 No testing is required
CLASSIFICATION
 Classifications are based on specific procedures outlined in the
regulations.
 Data is gathered on the substance/mixture and compared to the
criteria on the standard
 The resulting classification is referenced to the labeling
requirements and the resulting information is to appear on the
labels and Safety Data Sheets (SDS)
HEALTH/ENVIRONMENTAL HAZARD
CATEGORIES
Acute Toxicity
Skin Corrosion/Irritation
Serious Eye Damage/Eye Irritation
Respiratory or Skin Sensitization
Germ Cell Mutagenicity
Carcinogenicity
Reproductive Toxicity
Target Organ Systemic Toxicity – Single and Repeated Dose
Aspiration Toxicity
Hazardous to the Aquatic Environment (non-mandatory)
PHYSICAL HAZARDS
Explosive
Flammability – gases, aerosols, liquids, solids
Oxidizer – liquid, solid, gases
Self-Reactive
Pyrophoric – liquids, solids
Self-Heating
Organic Peroxides
Corrosive to Metals
Gases Under Pressure
Water-Activated Flammable Gases
REQUIRED LABEL ELEMENTS
 Product identifier
 Supplier identifier (name, address, phone)
 Hazard pictograms
 Signal words (Warning or Danger)
 Hazard statements
 Precautionary information
 Supplemental information is optional
Pictograms
HEALTH
HAZARD
FLAME
EXCLAMATION
MARK
GAS
CYLINDER
FLAME
OVER
CIRCLE
CORROSION
ENVIRONMENT
EXPLODING
BOMB
SKULL
&
CROSSBONES
• Acute Toxicity (fatal or toxic)
• Acute toxicity (harmful)
• Eye or skin irritant
• Skin sensitizer
• Respiratory tract irritant
• Narcotic effects
• Hazardous to the ozone
layer
• Corrosive to skin
• Eye damage
• Corrosive to metals
• Flammable
• Pyrophoric
• Self-heating
• Water activated flammable gas
• Self-reactive
• Organic peroxide
• Oxidizer
Gases under pressure
• Explosive
• Self-reactive
• Organic peroxide
•
•
•
•
•
•
Carcinogen
Mutagen
Reproductive toxicity
Respiratory sensitizer
Target organ toxicity
Aspiration toxicity
• Aquatic Toxicity
(non-mandatory)
Categories of Acute Oral Toxicity
Category 1
LD50 < 5 mg/kg
Category 2
Category 3
Category 4
LD50 > 5 to < 50 mg/kg LD50 > 50 to < 300 mg/kg LD50 > 300 to < 2000 mg/kg
DANGER
DANGER
DANGER
WARNING
Fatal if swallowed
Fatal if swallowed
Toxic if swallowed
Harmful if swallowed
EXAMPLE
 Cleaning product
 Calculated acute oral LD50 of 200 mg/kg (Category 3)
 No specific treatment or antidote
 Severe eye irritant (Category 2A)
 Not classified under any other category
Ultra-Super-Kleen
Pictograms
Product Identifier
DANGER
Signal word
Toxic if swallowed. Causes serious eye irritation.
Hazard Statements
Wash Hands thoroughly after handling. Do not eat, drink or smoke when using
this product. Wear eye protection (specify). Precautionary Statements-Prevention
If swallowed: Rinse mouth. Immediately call a doctor of poison control center.
If in eyes: Rinse cautiously with water for several minutes. Remove contact
lenses , if present and easy to do so. Continue rinsing. If eye irritation persists:
Get medical attention. Precautionary Statements-Response
Store Locked up. Dispose of in accordance with local, state and federal
regulations. Precautionary Statements- Storage & Disposal
The Kleen Corporation, 1234 Main Street, Chicago, Illinois 60608, 312-312-3121
Supplier Name, Address and Phone Number
FOR PROFESSIONAL
USE ONLY
SAFETY DATA SHEETS - 16 SECTION
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 and storage
8.
Exposure control/personal protection
SAFETY DATA SHEETS - 16 SECTION
9.
Physical and chemical properties
10.
Stability and reactivity
11.
Toxicological information
12.
Ecological information
13.
Disposal considerations
14.
Transport information
15.
Regulatory information
16.
Other information
GHS LABELS
VS.
GHS
GHS
 Labeling is a very prescriptive
process that requires the
product be classified and
labeled based on the strict
guidelines (hazard based)
 Pictograms
 Location and font size not
specified
CONSUMER LABELS
Consumer
Consumer
 More flexible assessment of risk
(risk based); labeling statements
are generally more flexible
 No pictogram required (usually)
 Location and font size
requirements well defined;
depends on many variables such
as container size
PROFESSIONAL LABEL
Ultra-Super-Kleen
DANGER
Toxic if swallowed. Causes serious eye irritation.
Wash Hands thoroughly after handling. Do not eat, drink or smoke when using
this product. Wear eye protection (specify).
If swallowed: Rinse mouth. Immediately call a doctor of poison control center.
If in eyes: Rinse cautiously with water for several minutes. Remove contact
lenses , if present and easy to do so. Continue rinsing. If eye irritation persists:
Get medical attention.
Store Locked up. Dispose of in accordance with local, state and federal
regulations.
The Kleen Corporation, 1234 Main Street, Chicago, Illinois 60608, 312-312-3121
FOR PROFESSIONAL
USE ONLY
CONSUMER LABEL
FRONT
PANEL
Ultra-Super-Kleen
CAUTION: Harmful if swallowed. Causes serious eye irritation.
See back panel for additional information.
BACK PANEL
Wash Hands thoroughly after handling. Do not eat, drink or
smoke when using this product. Avoid contact with skin and
eyes.
FIRST AID: If swallowed: Rinse mouth then immediately
call a doctor of poison control center. If in eyes: Rinse with
water for 15 minutes. If eye irritation persists seek medical
attention.
Keep out of the reach of children
The Kleen Corporation, Chicago, Illinois 60608
CAN YOU USE CONSUMER PRODUCTS IN
THE WORKPLACE?
 OSHA permits the use of consumer labeled products in the workplace.
 OSHA requires the employer to assess if consumer products in the
workplace are used in the same manner (frequency and duration) as a
consumer would use them.
 Products used in a manner similar to consumers does not require any
special training or SDS be obtained.
 Example – a glass cleaner used on your computer screen once a week
HAZCOM EXEMPTION FOR CONSUMER
PRODUCTS
§1910.1200 Hazard communication.
(b) Scope and application.
(6) This section does not apply to:
(ix) Any consumer product or hazardous substance, as those terms are
defined in the Consumer Product Safety Act and Federal Hazardous
Substances Act respectively, where the employer can show that it is
used in the workplace for the purpose intended by the chemical
manufacturer or importer of the product, and the use results in a duration
and frequency of exposure which is not greater than the range of
exposures that could reasonably be experienced by consumers when
used for the purpose intended
CONSUMER PRODUCT REQUIREMENTS WHEN
USED MORE FREQUENTLY IN THE WORKPLACE
 For example, a consumer labeled glass cleaner used by the
cleaning person on 100 windows daily
 This use greatly exceeds the frequency/duration of a typical
consumer
 OSHA requires that in this case, the employee be trained on the
use of the product
 A SDS is required if available (or documentation that it is not
available)
 It is acceptable to create you own SDS if you know enough
about the product.
FOR MORE INFORMATION
 A Guide to The Globally Harmonized System of Classification and Labelling of
Chemicals (GHS)
 https://www.osha.gov/dsg/hazcom/ghs.html
 Small Entity Compliance Guide for Employers That Use Hazardous Chemicals
 https://www.osha.gov/Publications/OSHA3695.pdf
 HCS/HazCom 2012 Final Rule & Appendices
 https://www.osha.gov/dsg/hazcom/ghs-final-rule.html
 UN Purple Book
 http://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev05/English/STSG-AC10-30-Rev5e.pdf
Rob Harrington, Ph.D.
Compliance Services International
rharrington@complianceservices.com
http://www.complianceservices.com/
630-222-7624