GHS and The 2012 Hazcom
Standard:
A YEAR-PLUS IN: WHAT TRAINERS NEED
TO THINK ABOUT NOW!
August 22nd, 2013
Labelmaster
Paul Burgess, DGSA
Regulatory Specialist
NKP 765 South at Jaite, Ohio, September 2010 Photo (c) Paul W. Burgess, all rights reserved
The Hazcom Train is leaving the Station!
Next Stop: Training for the GHS System!
Objectives for this Presentation
GHS Hazcom Summary
General Rule/Outline
Labeling and SDS Training Goals
Timeline and Impact – What You
Need to Think About NOW
A Little History
Early 70s – OSHA (Occupational Safety and
Health Administration) Established
1983 – Hazard Communication Rule (29 CFR
1910.1200) Initial Promulgation
1992 – Rio De Janeiro UN Conference Sets Goal
of a “Globally Harmonized System” of Hazard
Communication in Transportation and Workplace
by the Year 2000
What is GHS?
GHS (Globally Harmonized System) Joint Global
Framework of Guidelines Classifying and
Communicating Chemical Hazards
UN Created GHS, Updated as Conditions and
Knowledge Change
Current Iteration: 4th Revision. OSHA Hazcom
Based on 3rd Revision
What Isn’t GHS?
“GHS” Itself is NOT:
A Law
A Regulation
A Legal Standard
An Industry Best Practice
GHS is an Agreed Framework which Countries,
Groups and other Interested or Affected
Bodies can use to Create Harmonized Versions
of the Above
Benefits of GHS
Full Implementation will Make Hazcom
Understandable on a Global Basis
Ease Burden of Hazard Communication for Global
Trade/Remove “Technical Barrier” Some Countries
Use
Allow Workers to Change Jobs & Maintain
Familiarity with the System
 Best of All-Increased Worker Safety!
March 26th, 2012 – OSHA Acts
The New Hazcomm Standard Promulgated as a
Final Rule
Effective Date: May 25th, 2012
The Standard is Now in Place in the US
What Does it Do?
Keeps Most Basic Elements of old Hazcom
Standard in Place
Changes the “How”
Increases Worker Protection by Enhanced
Requirements for Hazard Communication
Labeling, Safety Data Sheets, & Strict
Classification of Hazards
Uses the GHS Rev. 3 as Baseline
Implementation Dates
Dec. 1, 2013
Employers must
train employees
on the new label
elements and
safety data sheet
(SDS) format
June 1, 2015
Chemical
manufacturers,
importers,
distributors and
employers must
comply with all
modified
provisions
Dec. 1, 2015
Distributors begin
shipping
containers labeled
by the
chemical
manufacturer or
importer with a
HCS label
June 1, 2016
Employers must
update
alternative
workplace labeling
and hazard
communication
programs as
necessary and
provide additional
employee
training for newly
identified
physical or health
hazards
Overview of:
29 CFR 1910.1200 (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.
What Has Changed?
The prior version of the Hazcomm standard did not
formally define “Classification” because that
standard required “assessment of hazard” rather
than “classification.”
Legal Requirements for Classification
29 CFR 1910.1200 (d)(1)
Chemical manufacturers and importers shall evaluate chemicals
produced in their workplaces or imported by them to classify the
chemicals in accordance with this section. For each chemical,
the chemical manufacturer or importer shall determine the
hazard classes, and where appropriate, the category of each
class that apply to the chemical being classified. Employers are
not required to classify chemicals unless they choose not to rely
on the classification performed by the chemical manufacturer or
importer for the chemical to satisfy this requirement.
The Bottom Line:
Old Standard: assumed hazard
classification already existed, at least to a
degree, and required assessment of already
postulated risk.
Hazcom 2012: requires an evaluation and
assignment of the classification of the
hazards themselves, along with assignment
of risk.
GHS Hazard Classifications
Physical Hazards
 Explosives
 Flammable Gases, Aerosols,
Liquids, Solids
 Oxidizers
 Self-Reactives
 Self-heaters
 Pyrophorics
 Organic Peroxides
 Corrosives
 Pressurized Gases
 Dangerous When Wet
Health/Environmental Hazards
 Acute Toxicity
 Aspiration
 Skin Corrosion and Irritation
 Respiratory and/or Skin
Sensitization
 Mutagenicity
 Carcinogenicity
 Reproductive Damage
 Organ Toxicity, Single and
Multiple Doses
 Danger to Aquatic
Environment
Label Elements:
Strictly Delineated by the regulation:
Pictographic and Textual Information for Use on
Hazard Warning Labels
Deliberate Goal of the GHS Alignment
 Rule allows use of separate workplace-only
systems provided that the GHS based system is
still used on all shipped containers and
employees are trained on both of the systems
and any differences between them
Labeling Under GHS-Based
Systems
GHS Labeling Largely Reflects Usage by
USDOT/ICAO/IMO Transport World
Internationally Recognized Pictograms
Designed to Limit Need for Language
Conversion from Country to Country
Hazard Symbols and Classes
Flame
Flame Over Circle
Exclamation Mark
Flammables
Self Reactives
Pyrophorics
Self-heating
Emits Flammable Gas
Organic Peroxides
Oxidizers
Irritant
Dermal Sensitizer
Acute Toxicity (harmful)
Narcotic Effects
Respiratory Tract Irritation
Explosives
Self Reactives
Organic Peroxides
Skull and Crossbones
Corrosion
Gas Cylinder
Health Hazard
Corrosives
Gases Under Pressure
Carcinogen
Respiratory Sensitizer
Reproductive Toxicity
Target Organ Toxicity
Mutagenicity
Aspiration Toxicity
Exploding Bomb
Acute Toxicity (severe)
Label Elements, Applied
Note: This is a fictitious example chemical
The SDS (Safety Data Sheet)
New Standard Converts Current Material Safety
Data Sheets (MSDS) to Safety Data Sheets (SDS)
Sections Harmonized with International
Requirements
Significantly More Information about
Product, Use & Handling
The SDS Format
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1910.1200(g)(2)(i) Section 1, Identification
1910.1200(g)(2)(ii) Section 2, Hazard(s) identification
1910.1200(g)(2)(iii) Section 3, Composition/information on ingredients
1910.1200(g)(2)(iv) Section 4, First-aid measures
1910.1200(g)(2)(v) Section 5, Fire-fighting measures
1910.1200(g)(2)(vi) Section 6, Accidental release measures
1910.1200(g)(2)(vii) Section 7, Handling and storage
1910.1200(g)(2)(viii) Section 8, Exposure controls/personal protection
1910.1200(g)(2)(ix) Section 9, Physical and chemical properties
1910.1200(g)(2)(x) Section 10, Stability and reactivity
1910.1200(g)(2)(xi) Section 11, Toxicological information
1910.1200(g)(2)(xii) Section 12, Ecological information
1910.1200(g)(2)(xiii) Section 13, Disposal considerations
1910.1200(g)(2)(xiv) Section 14, Transport information
1910.1200(g)(2)(xv) Section 15, Regulatory information
1910.1200(g)(2)(xvi) Section 16, Other information, including date of preparation or
last revision.
Note 1 to paragraph (g)(2): To be consistent with the GHS, an SDS must also include the headings
in paragraphs (g)(2)(xii) through (g)(2)(xv) in order.
Note 2 to paragraph (g)(2): OSHA will not be enforcing information requirements in sections 12
through 15, as these areas are not under its jurisdiction!
Training: The Initial Hurdle
Coming Right Up: On December 1st, 2013
Employers MUST Train Employees to Understand
and Use the New GHS-based System
Even if the System has not yet been Placed in
Service at the Place of Employment!
Training Requirements
1910.1200(h) Employee information and
training.1910.1200(h)(1) Employers shall provide
employees with effective information and
training on hazardous chemicals in their work
area at the time of their initial assignment, and
whenever a new chemical hazard the employees
have not previously been trained about is
introduced into their work area. Information and
training may be designed to cover categories of
hazards (e.g., flammability, carcinogenicity) or
specific chemicals. Chemical-specific
information must always be available through
labels and safety data sheets
Informing Your Staff
1910.1200(h)(2) Information. Employees shall be
informed of: 1910.1200(h)(2)(i) The requirements of
this section;1910.1200(h)(2)(ii) Any operations in
their work area where hazardous chemicals are
present; and,1910.1200(h)(2)(iii) The location and
availability of the written hazard communication
program, including the required list(s) of hazardous
chemicals, and safety data sheets required by this
section.
Basic Training Summary
Requirements due by 1
December:
Label Elements
SDS Format and Content
Document this Training!
25
What You Need To Think About Now
TRAIN YOUR EMPLOYEES
December 1, 2013 Establishes that ALL Employees
be Trained – that is only 3 months away!
Most Employers Conduct “Right to Know”
Training Yearly
Now is Optimal Time to “Convert”
This is a Large Change—
Don’t Wait Until the Last
Minute! (Which is almost here)
How Can Labelmaster Help?
THE LABELMASTER GHIS SYSTEM:
Globally Harmonized Information System (GHIS)
Training
SDS
Labeling
Training Products
LABELMASTER GHIS SYSTEM:
 Training Programs (Online & Book Formats)
 Instructor’s Resources on USB
 Student, Instructor & Implementation Manuals
 Training Kits and Reference Tools (Posters and Cards)
Resources
WWW.Labelmaster.com/GHS
Senior GHS Liaison: Estuardo Sanchez:
ESANCHEZ@labelmaster.com
GHS Regulatory Liaison: Paul Burgess, DGSA :
PBURGESS@labelmaster.com
Extensive information and assistance available on
Department of Labor/OSHA websites
Information on the UN GHS Program Itself Can Be
Found on the UN Website
Many Local Governments also Offer Assistance
The Wrap Up
Questions? Clarifications?
Want more? See our comprehensive
Webinars. GHS Parts I through IV are
Available on our Website:
labelmaster.com/ghs
Thank You So Much for Your Interest!