OSHA
HAZARD
COMMUNICATION
UPDATE
Kim G. Auletta
Stony Brook University
June 2012
Have you started using any GHS elements
in your Hazard Communication training?
A
•Yes
B
•No
C
•Don’t know what GHS is
Topics
Major
Changes
Why
Update
Written
Program
Training
Changes in
Definition
Hazard
Classification
List of
Chemicals
Labels
Safety Data
Sheets
To Do List
Other
Affected OSHA
Standards
Effective
Dates
Resources
Major Changes
Information
and Training
Hazard
Classification
Safety Data
Sheets
Labels
All
Laboratories
Health Care
Facilities
Who is
Affected
Museum
Visual Arts
Theater
Why Did OSHA Update HazCom?
To improve the safety and health of workers
through more effective communications on
chemical hazards
Right to
Know
Right to
Understand
Benefits to Update
Performance Oriented Led to
Confusion
Standardized Approach
Improved Comprehension
of the Standard
Safety Data Sheets Standardized
Changes to Definitions
Delete
Added
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Combustible Liquid
Compressed Gas
Explosive
Flammable
Flashpoint
Hazard Warning
Identity
Material Safety Data Sheet
Organic Peroxide
Oxidizer
Pyrophoric
Unstable (reactive)
Water Reactive
Classification
Hazard Category
Hazard Class
Hazard not otherwise classified
Label Elements
Pictogram
Precautionary Statement
Product Identifier
Pyrophoric Gas
Safety Data Sheet
Signal Word
Simple Asphyxiant
Substance
Revised Definitions
Chemical
Chemical
Name
Hazardous
Chemical
Health
Hazard
Label
Mixture
Physical
Hazard
Trade
Secret
Chemical
OLD
NEW
Any
substance or
mixture of
substances
Any element,
chemical
compound or
mixture of
elements and/or
compounds
Chemical Name
OLD
The scientific designation of
a chemical in accordance
with the nomenclature
system developed by the
International Union of Pure
and Applied Chemistry
(IUPAC) or the Chemical
Abstracts Service (CAS) rules
of nomenclature, or a name
which will clearly identify the
chemical for the purpose of
conducting a hazard
evaluation.
NEW
The scientific designation of
a chemical in accordance
with the nomenclature
system developed by the
International Union of Pure
and Applied Chemistry
(IUPAC) or the Chemical
Abstracts Service (CAS) rules
of nomenclature, or a name
that will clearly identify the
chemical for the purpose of
conducting a hazard
classification
Hazardous Chemical
OLD
NEW
Any chemical
which is a
physical hazard
or a health
hazard
Any chemical which is
classified as a physical
hazard or a health
hazard, a simple
asphyxiant,
combustible dust,
pyrophoric gas, or
hazard not otherwise
classified
Health Hazard
OLD
A chemical for which there is statistically
significant evidence based on at least one study
conducted in accordance with established
scientific principles that acute or chronic health
effects may occur in exposed employees.
The term "health hazard" includes chemicals which are:
• carcinogens, toxic or highly toxic agents,
reproductive toxins, irritants, corrosives, sensitizers,
hepatotoxins, nephrotoxins, neurotoxins, agents
which act on the hematopoietic system, and agents
which damage the lungs, skin, eyes, or mucous
membranes.
Appendix A provides further definitions and explanations
of the scope of health hazards covered by this section.
Appendix B describes the criteria to be used to determine
whether or not a chemical is to be considered hazardous
for purposes of this standard.
NEW
A chemical which is classified as posing
one of the following hazardous effects:
• 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); or aspiration hazard.
The criteria for determining whether a
chemical is classified as a health hazard
are detailed in Appendix A to
§1910.1200 -- Health Hazard Criteria
Label
OLD
NEW
Any written,
printed, or graphic
material displayed
on or affixed to
containers of
hazardous
chemicals
An appropriate group of
written, printed or graphic
information elements
concerning a hazardous
chemical that is affixed to,
printed on, or attached to
the immediate container of
a hazardous chemical, or to
the outside packaging.
Mixture
OLD
NEW
Any combination of
two or more
chemicals if the
combination is not,
in whole or in part,
the result of a
chemical reaction
A combination or a
solution composed
of two or more
substances in
which they do not
react
Physical Hazard
OLD
NEW
A chemical for which
there is scientifically valid
evidence that it is a
combustible liquid, a
compressed gas,
explosive, flammable, an
organic peroxide, an
oxidizer, pyrophoric,
unstable (reactive) or
water-reactive.
A chemical that is classified as
posing one of the following
hazardous effects: 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; or in
contact with water emits
flammable gas. See Appendix B to
§1910.1200 -- Physical Hazard
Criteria.
Trade Secret
OLD
NEW
Any confidential formula,
pattern, process, device,
information or compilation of
information that is used in an
employer's business, and that
gives the employer an
opportunity to obtain an
advantage over competitors who
do not know or use it. Appendix
D sets out the criteria to be used
in evaluating trade secrets.
Any confidential formula, pattern,
process, device, information or
compilation of information that is
used in an employer's business,
and that gives the employer an
opportunity to obtain an
advantage over competitors who
do not know or use it. Appendix E
to §1910.1200–Definition of Trade
Secret, sets out the criteria to be
used in evaluating trade secrets.
Specific Criteria
2012 Approach
Different from
1994
Hazard
Classification
Appendices
A&B
No Additional
Testing
Category
1
Manufacturer’s
Responsibility!
Hazard
Category
Hazard
Class
Hazard
Classification
Evaluation
Category
2
Example: Acute Toxicity
Mixtures
OLD
Include all
hazardous
chemicals >1% or
carcinogens >0.1%
NEW
% changes depends
on hazard class and
category
Safety Data
Sheets
New Labeling
Format
Written
Program
No “Substantive”
Changes
Possible Changes
to Chemical List
List of Chemicals
Identity
Product
Identifier
Do you think the new Hazard Communication
requirements will:
A
B
C
• Provide the workers with a better understanding of
the chemical hazards they may be exposed to
• Create more work for our overburdened EH&S staff
• Don't expect any changes in our program
Labels
Provides detailed and specific labeling requirements.
No longer performance oriented approach.
Once a chemical is classified, specific label
elements and information for each hazard class and
category are required.
Requires pictograms, signal word, and hazard &
precautionary statements on labels.
Product
Identifier
Precautionary
Signal Word
Statements
Label
Elements
Manufacturer’s
Responsibility
Hazard
Statement
including
Hazard Class
and Category
Pictogram
Supplier &
Manufacturer
Name,
Address &
Phone
Specified
pictogram, hazard
statement, signal
word and
precautionary
statement for
each hazard class
and category.
Appendix C provides required elements for each hazard class and category
http://www.osha.gov/FedReg_osha_pdf/FED20120326.pdf page 251
Pictograms
Oxidizers
Explosives
Self Reactives
Organic Peroxides
Corrosives
Flammables
Pyrophorics
Self-Heating
Emits Flammable
Gas
Acute Toxicity
(severe)
Gases under
pressure
Carcinogen
Mutagenicity
Reproductive Toxicity
Respiratory Sensitizer
Target Organ Toxicity
Aspiration Toxicity
Aquatic Toxicity
Irritant
Skin Sensitizer
Acute Toxicity (Harmful)
Narcotic Effects
Respiratory Tract Irritation
Hazardous to Ozone Layer
http://www.osha.gov/Publications/OSHA3492QuickCardLabel.pdf
In House Labels
Alternatives are permitted for in house labeling
BUT the information must be consistent with
the new format and label elements.
Product
identifier and
words, pictures,
symbols or
Original label or
combination to
provide general
information on
the hazards
Hazard
classification
system must be
consistent with
updated GHS
Safety Data Sheets
Specific sections and the order they are to be
listed on the Safety Data Sheets are now
required.
16-section format similar to the ANSI standard for Hazardous
Workplace Chemicals-Hazard Evaluation and Safety Data
Sheets and Precautionary Labeling Preparation (ANSI Z400.1 &
Z129.1 - 2010).
Uniformity will improve the effectiveness of
the safety data sheet.
Safety Data Sheet
• Identification
1
• Identifies the chemical, recommended uses and the essential contact information
of the supplier.
• Hazards Identification
2
• Identifies the hazards of the chemical and the appropriate warning information
associated with those hazards.
• Composition/Information on Ingredients
3
• Identifies the ingredient(s) in the product, including impurities and stabilizing additives
and any trade secret claims.
• First Aid Measures
4
• Describes the initial care that should be given by untrained responders to an individual
who has been exposed to the chemical.
Safety Data Sheet
• Fire Fighting Measures
5
• Recommendations for fighting a fire caused by the chemical.
• Accidental Release Measures
6
7
8
• Recommendations on the appropriate response to spills, leaks, or releases.
• Handling and Storage
• Guidance on the safe handling practices and conditions for safe storage.
• Exposure Controls & Personal Protection
• Exposure limits, engineering controls, and personal protective measures.
Safety Data Sheet
9
• Physical and Chemical Properties
10
• Stability and Reactivity
11
• Toxicological Information
12
• Ecological Information
Safety Data Sheet
13
• Disposal Considerations
14
• Transport Information
15
• Regulatory Information
16
• Other information including date
of preparation or last revision
GHS SDS Elements
Signal words: “Danger” or “Warning”
72 individual and 17 combined Hazard
Statements
116 individual and 33 combined
Precautionary Statements
Statement Summary
http://www.sigmaaldrich.com/safety-center/globally-harmonized.html
Methanol SDS from Sigma
Completed by
December 1, 2013
Not required to address
the specific hazards of
the chemicals or the
protective measures
GHS
Training
All training provisions
remain the same as
the HCS 1994
OSHA provides no new
guidance on HOW to
provide training on
new SDS & labels
To Do
Train all employees in new SDS
format
• Include:
• The order of information on the SDS
• How employees can obtain SDS
• How to obtain and use the appropriate hazard
information
• http://www.osha.gov/dsg/hazcom/osha-brief.html
To Do
Train all employees in new
label format
• Include:
• Product Identifier
• Signal words (Danger & Warning)
• Pictograms
• Hazard Statements
• Precautionary Statements
•
http://www.osha.gov/Publications/HazComm_QuickCard_Labels.html
Chemical Game
Chemical Game
1. Which PICTOGRAM is on the Clorox Bleach container?
a. Health Hazard
b. Exploding Bomb
c. Corrosion
d. Skull & Crossbones
2. Which Section # on the SDS will you find what kind of gloves you need to wear?
a. Section 1
b. Section 5
c. Section 8
d. Section 11
3. Which product will have a HEALTH HAZARD Pictogram?
a. Asbestos
Given to staff after providing
b. Acetic Acid
copies and reviewing the OSHA
c. Ammonia
Quick Cards for Pictograms,
d. Anise
Labels and SDS
4. Which SIGNAL WORD is the greater hazard?
a. Danger
b. Warning
5. Which section of the LABEL will tell you how to handle the product safely?
a. Identifier
b. Pictogram
c. Hazard Statement
d. Precautionary Statement
Quiz
To Do
Train employees in new hazard classes that may
not have been covered in previous program.
• Simple asphyxiant
• Pyrophoric gas
• Combustible dust
• Hazard not otherwise classified
• Update Haz Com Training for all new employees
No later than June 1, 2016
Other OSHA Standards
1910.106 Flammable Liquids
• Not more than 60 gallons of Category 1, 2, or 3 flammable liquids, nor
more than 120 gallons of Category 4 flammable liquids may be stored in
a storage cabinet.
Container
Cat 1
Cat 2
Cat 3
Cat 4
Glass or approved plastic
1 pt
1 qt
1 gal
1 gal
Metal
1 gal
5 gal
5 gal
5 gal
Safety Cans
2 gal
5 gal
5 gal
5 gal
Definition Changes
1910.107
Spray finishing using flammable and combustible materials
1910.119
Process safety management of highly hazardous chemicals
1910.120
Hazardous waste operations and emergency response
1910.123
Dipping and coating operations
1910.252
Welding, Cutting and Brazing
1910.1450
Occupational exposure to hazardous
chemicals in laboratories
Changes to definitions only to align terms with GHS
• Removed combustible liquid, compressed gas, explosive, flammable,
flashpoint, organic peroxide, oxidizer, unstable (reactive), waterreactive
• Revised hazardous chemical, physical hazard, reproductive toxins
• Added health hazard, mutagen
• Changed “material safety data sheet” to “safety data sheet”
No changes to any requirements, including
labeling
Definitions, Signs and Labels
1910.1001 Asbestos
1910.1003 “13 Carcinogens”
1910. 10xx
• Specific chemical standards
1910.1048 Formaldehyde
Signs for Regulated Area
• DANGER FORMALDEHYDE
• MAY CAUSE CANCER
• CAUSES SKIN, EYE, AND RESPIRATORY IRRITATION
• AUTHORIZED PERSONNEL ONLY
Labels for containers of contaminated clothing & equipment
• DANGER FORMALDEHYDE-CONTAMINATED [CLOTHING] EQUIPMENT
• MAY CAUSE CANCER
• CAUSES SKIN, EYE, AND RESPIRATORY IRRITATION
• DO NOT BREATHE VAPOR DO NOT GET ON SKIN
Communication
• Classify the hazards of formaldehyde to include: Cancer; skin and respiratory sensitization; eye,
skin and respiratory tract irritation; acute toxicity effects; and flammability
• Material capable of releasing formaldehyde at levels above 0.5 ppm: labels shall address all
hazards, including cancer and respiratory sensitization, and shall contain the hazard statement
"May Cause Cancer."
• Materials capable of releasing formaldehyde at levels of 0.1 ppm to 0.5 ppm: labels shall identify
that the product contains formaldehyde; list the name and address of the responsible party; and
state that physical and health hazard information is readily available from the employer and from
safety data sheets.
Effective Dates
Employers must train employees on the new label
elements and safety data sheet format by
December 1, 2013
All other provisions are to be in effect by June 1,
2016
• distributors to ensure all manufacturer labels are updated.
• all employers must ensure that updated workplace signs,
hazard communication program, and training necessary for
newly identified physical or health hazards are in place.
Resources
OSHA
• http://www.osha.gov/dsg/hazcom/index.html
NIOSH/ICSC Cards
• http://www.cdc.gov/niosh/ipcs/icstart.html
Sigma Aldrich
• http://www.sigmaaldrich.com/safety-center/globally-harmonized.html
EU List of Chemicals with Classification
• http://echa.europa.eu/web/guest/information-on-chemicals/cl-inventory-database
New Zealand List of Chemicals with Classification
• http://www.epa.govt.nz/search-databases/Pages/HSNO-CCID.aspx
Japan List of Chemicals with Classification
• http://www.safe.nite.go.jp/english/ghs_index.html#results
How do you plan on providing GHS training
on labels and SDS to your campus?
A
•Live training classes
B
•Handouts
C
•On-line mandatory training
QUESTIONS?
Contact:
Kim Gates Auletta
Environmental Health & Safety
Stony Brook University
Kim.auletta@stonybrook.edu
631-632-3032
http://www.stonybrook.edu/ehs/lab/