65th Annual
Wilmington Regional Safety & Health School
July 30 & 31, 2015
Globally Harmonized System
(HazCom) Compliance
Chuck Haling
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GHS: 2
Deadlines
Hit in 2015
Are You
Ready?
Chuck Haling
VP of Sales, MSDSonline
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Presentation Goals
 Review OSHA’s HCS and
UN’s GHS
 Discuss OSHA’s adoption
of GHS and resulting
HazCom changes
 Review deadlines and
expectations
 Describe ways to manage
the GHS transition to
ensure compliance
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What is HCS?
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HCS
Right
to
HazComm
1910.
1200
HazCom
1994
Know
Hazard
Communication
29 CFR
1910.
1200
The
Reg
The
RTK
Haz
Com
HazCom
Standard
HazCom
Reg
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What is HCS?
• Hazard Communication Standard
• OSHA Regulation - Protects workers
from hazardous chemicals
• Adopted in 1983
• Covers 43 million U.S. workers
and 5 million workplaces
• Covers 880,000+ chemicals and
millions of safety data sheets
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Why Are We Reviewing
HazCom Basics?
A: Because a lot of the compliance
questions OSHA receives about GHS,
actually pertain to obligations that have
been in place for decades under the preGHS-aligned HazCom Standard.
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A:
Many of the ‘GHS’ compliance
questions OSHA receives
actually pertain to obligations that
have been in place for decades
under the pre-GHS-aligned
HazCom Standard
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Penalties for Noncompliance Are Real
• From 2009 – 2014 OSHA
cited over 37,000
instances of HCS
violations in workplaces
across the United States
• Ranked #2 on OSHA’s top
10 list of most frequently
cited standards in 2012,
2013 & 2014 and #3 in
previous years
Source: www.OSHA.gov
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Who has Responsibilities
under HCS?
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3 Groups Have Responsibilities
1
Chemical
Manufacturers
• Evaluate and
now also
classify
hazards of
chemicals
• Provide
Labels &
MSDSs to
downstream
users
2
Chemical
Importers &
Distributors
• Provide
Labels &
MSDSs to
Employers
they ship to
3
Employers: End-Users
of Chemicals
Components of Compliant
HazCom Program:
1. Written HazCom Plan
2. Chemical Inventory List
3. Proper Labels and
Warnings
4. MSDSs and Right-toKnow Access
5. Training
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Why the
Need
for GHS
OSHA seems to
have things covered
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Hazardous chemical
regulations vary by country
Results in
International
trade barriers
Confusion for
end-users
Extra time and $
to manage
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GHS
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With GHS,
Countries' hazardous chemical regulations
become more aligned
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• GHS = Globally Harmonized System
of Classification and Labelling
of Chemicals
• UN 1st edition published in 2003
• Result of 1992 Rio Earth Summit
• OSHA chaired The Coordinating
Group that developed the system
• Common & coherent
global approach
• To Classifying, Defining
and Communicating Hazards
• Provides Consistency/ Harmonization to Labels
and Safety Data Sheets
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adoption of
GHS
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adoption of GHS
• Final Rule went into effect May 2012
• Based on UN's GHS Rev. 3 (2009)
• HCS framework remains
(Bulk of Technical Info is Located in
Appendices)
• Aims to Enhance Protections
• Phased-in process
• During transition can comply with old,
new, or a combo of old and new HazCom
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HazCom 2012
Right-to-Understand
(RTU) Standard
"The standard that gave workers the right to
know, now gives them the right to understand."
Source: OSHA's HazCom Web page
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UN Updates GHS Every
…
years
OSHA has
long-term
action
goal to
align with
Rev. 6
RIN 1218-AC93: OSHA considering adopting Rev. 6 hazard
categories: Desensitized explosives and Pyrophoric gases
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HazCom 2012 Appendices
Appendix A: Health Hazard Criteria
Appendix B: Physical Hazard Criteria
Appendix C: Allocation of Label Elements
Appendix D: Safety Data Sheets
Appendix E: Definition of "Trade Secret”
Appendix F: Guidance for Hazard Classification
Regarding Carcinogenicity
Recipe
Book
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FAQ1:
What is my Deadline
to Comply?
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GHS Alignment Timeline
1
2
3
4
ANYTIME
during
Transition
• Dec. 1, 2013 ─ EMPLOYERS
• Train on new label elements and SDS format
Ongoing
Obligation
• June 1, 2015 ─ MANUFACTURERS, DISTRIBUTORS & IMPORTERS
• Reclassify chemicals, and update all SDSs and labels to GHS
Also
format
applies to
EMPLOYERS
• Dec. 1, 2015 ─ DISTRIBUTORS
who
• Begin sending only GHS-labeled products and safety data
choose to
sheets
perform the
classifica• June 1, 2016 ─ EMPLOYERS
tions
• Update alternative workplace labeling and HazCom Program
instead of
as needed, and provide addtl. employee training for newly
identified physical or health hazards
relying on
Mfr/Distr/
• EMPLOYERS, MANUFACTURERS and DISTRIBUTORS
Imptr
• Comply with either HazCom 1994, or HazCom 2012, or both
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Why Employer Training is Important…
Do your employees
know what this is?
Pictogram
Gas Cylinder
Used for indicating
Gases Under Pressure
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GHS Compliance
Waterfall Effect for
June 1, 2015
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Chemical Blenders . . .
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Deadline
Did Not Change
On Oct. 31, 2014
OSHA responded to ACA’s
petition for relief from the
June 1, 2015 deadline, saying its
June 1 deadline would not change
However, OSHA is willing to use
“enforcement discretion” to
determine if a good faith effort has
been made to comply
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owners.
Image
Source: MSDSonline EHS Blog
OSHA Enforcement Memo
issued Feb. 9, 2015 for Chemical Manufacturers, Distributors &
Importers of chemical mixtures
Applies to June 1, 2015 Effective Date
• “Reasonable Diligence” &
“Good Faith Effort” criteria
• Time period to develop HCS2012 compliant SDSs & Labels
•
•
SDSs: 6 months from receiving info
from supplier
Labels: 6 months after SDS is created
• Distributors can ship chemicals
labeled with HCS-1994 compliant
labels until Dec. 1, 2017
• If criteria in memo apply
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Image Source: OSHA Website
June 1 Interim OSHA
Enforcement Guidance
issued May 29, 2015
• NEW: Stock packaged
pre-June 1 can be
shipped with its older
labels post-June 1 …
BUT shipments
must include
HCS 2012-compliant
Labels and SDSs for each
and every individual container shipped
•
unless able to demonstrate reasonable diligence and good faith as
discussed in the policy
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FAQ2:
What are the Biggest
Changes to HazCom
as a Result of GHS Adoption?
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At a High
Level,
Much is the Same
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Two Most Prevalent Changes
1) Hazard Classification Criteria
• Health Hazards
• Physical Hazards
• Mixtures
2) Hazard ‘Communication’
• Labels
• Safety Data Sheets
• Training
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Under New OSHA Definition…
“Hazardous Chemical” means any chemical
which is classified as a
1)
2)
3)
4)
5)
6)
Physical hazard; or
Health hazard; or
Simple asphyxiant; or
Combustible dust; or
Pyrophoric gas; or
Hazard Not Otherwise
Classified (HNOC)
OSHA added 3 classes of chemicals that were
defined in its HCS 1994, but weren’t in the UN's GHS Rev.3
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The way chemicals are
classified has changed
• New definition of hazardous chemical
• New concept of severity
• Adds layers and categories
to hazard class
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OSHA added this definition to HazCom
"Classification
means to identify the relevant data
regarding the hazards of a chemical; review
those data to ascertain the hazards
associated with the chemical; and decide
whether the chemical will be classified as
hazardous according to the definition of
hazardous chemical ...” AND to determine
the "degree of hazard, where appropriate.."
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UN's GHS Hazard Classifications
• Physical
•
•
•
•
•
•
•
•
•
•
Explosives
Flammable – Gases,
Aerosols Liquids, Solids
Oxidizers– liquids, solids,
gases
Self-Reactive Substances
Self-Heating Substances
Pyrophoric – liquids, solids
Organic Peroxides
Corrosive to Metals
Gases Under Pressure
Water-Activated
Flammable Gases
New to HCS with GHS adoption
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UN’s GHS Hazard Classifications
• Health & Environmental
•
•
•
•
•
•
•
•
•
Acute Toxicity
Aspiration 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
• Hazardous to the Aquatic
Environment/Aquatic Toxicity
New to HCS with GHS adoption
• Hazardous to the Ozone Layer
Outside OSHA’s Jurisdiction
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GHS / HazCom 2012 Classification
Example of Classification Criteria with Categories
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HazCom 1994 vs HazCom 2012
HCS/HazCom 1994
• Gases Under Pressure
• Carcinogenicity
GHS Alignment/ HazCom 2012
• Compressed Gases
• Refrigerated Gases
• Liquefied Gases
• Dissolved Gases
• Carcinogenicity
• Category 1
• 1A = Known
• 1B = Probable
• Category 2
• Suspected
Note the numbering scheme: Lower the
#, the more severe the hazard
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FAQ3:
What are the New
Label Requirements?
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2 Types of Labels with
2 Different Requirements
1) Shipped Container Labels
2) Workplace Container Labels
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6 Main Elements - Shipped Label
1) Product/Chemical Identifier
2) Signal Word*
• Danger or Warning
3) Pictograms*
4) Hazard Statements*
5) Precautionary Statements**
• 4 Types: Prevention/ Response/
Storage / Disposal
6) Supplier Identifier
Addtl. non-conflicting info is permitted
* Standardized under GHS
** Standardized under HCS
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9 GHS Pictograms
Exploding Bomb
Explosives
Self Reactive
Organic Peroxide
Gas Cylinder
Flame
Flame Over Circle
Flammable
Self Reactive
Pyrophoric
Self-Heating
Emits Flammable Gas
Organic Peroxides
Skull and Crossbones
Gases Under
Pressure
Health Hazard
Carcinogenicity
Respiratory Sensitizer
Reproductive Toxicity
Target Organ Toxicity
Mutagenicity
Aspiration Toxicity
Acute Toxicity
(Fatal or toxic)
Exclamation Mark
Skin & Eye Irritant
Dermal Sensitizer
Acute Toxicity (Harmful)
Narcotic Effects
Respiratory Tract Irritant
Harmful to Ozone Layer
(Not mandatory)
Oxidizers
Corrosion
Skin Corrosion/
Burns
Corrosive to
Metals
Serious Eye
Damage
Environment
(Not mandatory for
HazCom 2012)
Aquatic Toxicity
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Labeling Small Containers
“Labeling can be done with
pull-out labels, fold back labels,
tags or other methods. While pullout labels, fold back labels, tags or other
methods to attach the label to the shipped
container may cost more than traditional
glued on labels, an increase in cost
is an
unacceptable reason to avoid
use of these labeling methods.”
— OSHA Letter of Interpretation, 6/04/13
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Labeling Individual Containers
“OSHA’s expectation
is that the immediate
container of the hazardous
chemical is labeled.”
— OSHA Letter of Interpretation, 6/04/13
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2 Types of Labels with
2 Different Requirements
1) Shipped Container Labels
2) Workplace Container Labels
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Workplace Labels
Requirements
Requirements
for
Shipped
Labels
for
Workplace
Labels
Compliance is now
prescriptive
Compliance is still
performance-based
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Workplace Labeling Options
1
Replicate
Manufacturer
Shipped Label
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Workplace Labeling Options
2
Use Combination of
GHS Label Elements
that + Training + Other Info
immediately available
to employees, provides
specific hazard details
Acetone
Highly Flammable
Use in well-ventilated
area
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Workplace Labeling Options
3
Use Homegrown
System
so long as employees
have info on all health
and physical hazards
Acetone
Highly Flammable
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Workplace Labeling Options
Also, continue to use
NFPA or HMIS systems
so long as:
1. Product Identifier is provided
Acetone
Highly Flammable
Use in well-ventilated
area
2. Info is consistent with HazCom
requirements
3. Employees have immediate
access to specific hazard
info and are fully aware of
all chemical hazards (chronic and acute)
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Workplace Labeling Compliance
Training
Workplace
Label
Workplace
Label
System
Other Info in
Workplace
Provides
employees
with
immediate
access to all
hazard
information
about a
chemical
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Shipped & Workplace Labels
• Must not be removed or defaced
• Unless immediately replaced
• Must be legible and prominently displayed
• Must be in English
• Other languages permitted (in addition to English)
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FAQ4:
How are Material
Safety Data Sheets
Changing?
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The NAME changes, but NOT THE PURPOSE
=
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Safety Data Sheets
• Redefined as Safety Data Sheets (SDS)
• Prescribed, strictly ordered 16-section format
• Essentially the ANSI Standard
• Several Sections of Info Not Mandatory
• Sections 12-15
•
•
•
•
Ecological information
Disposal considerations
Transport information
Regulatory information
=
• Outside of OSHA’s jurisdiction
• HCS Appendix D
• Details what is to be included in each section
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Safety Data Sheets – Headings
1. Identification
2. Hazard(s) Identification
9. Physical & Chemical
Properties
3. Composition/Ingredient
Information
10. Stability & Reactivity
4. First-Aid Measures
12. Ecological Information
5. Fire-Fighting Measures
13. Disposal Considerations
6. Accidental Release
Measures
14. Transport Information
7. Handling and Storage
16. Other Information
8. Exposure Control/
Personal Protection
11. Toxicological Information
15. Regulatory Information
NOTE: All headings and sections
must appear on SDS
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Safety Data Sheets
• Section 1 - Product Identifier
• Section 2 – Hazard(s) Identification
 GHS Classification
 Pictograms
 Signal Word
 Hazard
Statement
XYZ Chemical
 Precautionary
Statement
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SDS Quick Note
Unlike the requirement for Labels,
Pictograms on SDSs may be represented like:
OR
OR
Skull &
Crossbones
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Are you Prepared for
the MSDS Churn?
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Manufacturer Distribution of SDSs
June 1, 2015 - Manufacturers must begin using and
providing newly formatted SDSs with their shipments to
downstream users
Manufacturers are still only required to
provide new safety data sheets:
1) With initial shipments
2) With next shipment after an SDS has
been updated
3) When requested by downstream users
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Your Roadmap to Compliance
with OSHA’s GHS Deadlines and Modified HCS
No Chemical Left Behind
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Must-Dos and Haves
 Designate GHS Transition Leader
 Get and Stay Educated on GHS
• It's updated every 2 yrs. V5 was released in 2013. OSHA is
already looking to align with V6, per 2014 Fall Unified Agenda
 Update HazCom Plan
 Train and Prepare Employees
 Ensure Existing Systems Can Handle Transition
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Start by taking
Inventory
of current Chemicals and SDSs
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Walk the Floor & Catalog
 Physically tour entire facility
 Jot down all products, including consumer
products in non-consumer quantities
(1 Wite-Out may not be covered by HazCom, but a storage
closet of them might be.)
 Include:
•
•
•
A: Product Name & Manufacturer
B: Product Code, Supplier
C: Storage Location
 Be sure to:
•
•
Tour all areas (old storage areas, inside/outside, etc.)
Include general supplies (paints, fertilizers, general
cleaning supplies, etc.)
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Use
Chemical Inventory
List as Checklist to
Manage
Churn of
Labels and MSDSs
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Label Strategy
know what to do about the old and the new
─ What is your process for updating labels?
─
Are your employees aware of that process?
─ Who is responsible for updating your labels?
─ Is that person checking to make sure labels aren't
damaged or defaced?
─ Do you need to purchase new equipment in order to
print labels?
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Managing Old Labels
“Employer is not responsible for updating labels on
shipped containers, even if the shipped
containers are labeled under HazCom 1994.”
– OSHA Brief Hazard Communication Standard: Labels and Pictograms
Employer responsibilities are limited to
updating workplace labels to account for
any newly identified hazards, and also
training employees on those hazards.
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Have an MSDS to SDS
Strategy
know what to do with the old and the new
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MSDS to SDS Strategy
─
Who is responsible for managing your MSDS inventory?
─
Is that person checking for HazCom GHS-formatted SDSs?
─
Have employees been trained on the new SDS format?
─
Are you continuing to train on the pre-GHS formats?
─
How are you obtaining documents today / what is your plan for
getting new SDSs?
─
What happens when an SDS arrives in your inventory/ or what will
happen when it doesn’t?
─
─
Do your employees know what to do?
Does your Written HazCom Program include your plans for
managing documents during the GHS transition?
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Employer To-Dos for SDSs
 If you do not receive an SDS, request one ASAP
 Contact your supplier and request documents
 Show good faith effort
 Do not allow workers to use hazardous chemicals for which you
have not received an SDS
 If you receive an SDS that is inadequate, you must request an
appropriately completed one
 If your request does not produce the information needed, contact your local
OSHA area office for assistance in obtaining the SDS
 Some suppliers provide SDSs for products that are not
hazardous. These SDSs do not have to be maintained
 OSHA provided enforcement leniency to suppliers who meet
certain criteria. Be aware that this affects your timelines for
receiving updated labels and SDSs.
Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
Managing Older Versions of MSDSs
OSHA requires employers to
retain exposure records by:
• Archiving safety data sheets
or
• Maintaining a list of chemicals,
+ where + when chemicals
were used or stored
Requirement of 1910.1020 –
Access to Employee Exposure to Medical Records
Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
NEW July 9, 2015
OSHA HazCom 2012 / GHS
Enforcement Directive
• NEW: Specifies that employers
must not require employees to
perform Internet searches
(i.e., Google and Yahoo) to view
and obtain SDSs
• Employers may make
SDSs available on a
company website or
contract with
a Web-based SDS
service provider
Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
NEW July 9, 2015
OSHA HazCom 2012 / GHS
Enforcement Directive
• NEW: Specifies that employers using the same
product but from multiple manufacturers,
must maintain corresponding SDSs for each
product to be compliant
Acetone
123
Company
Acetone
123
Company
Acetone
XYZ
Company
Acetone
ABC
Company
Acetone
ABC
Company
Acetone
XYZ
Company
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How is your
HazCom Program
affected by GHS?
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GHS Affects Entire HazCom Program
1. Written Plan
• Must reflect GHS changes.
2. Chemical Inventory List
• Must update if reclassification results in new
hazardous chemicals.
3. Labels & Warnings
• Must update with new hazard info if warranted by
reclassification process. Consider aligning with the new
Shipped Label format.
4. Training
• Must include GHS changes to SDSs and Labels, any
newly identified hazards, and changes to Written Plan.
5. Safety Data Sheets
• Mix of formats will exist in inventory. Should describe plan
for managing these and ensure employee training on
both.
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GHS NEWS
 Feb. 11, 2015 Canada adopted GHS at Federal level
 Territories and Provinces must still adopt
 WHMIS 2015 replaces WHMIS 1988
 Hazardous Products Regulations
(HPR) replaces Controlled Products
Regulations (CPR) & Ingredient Disclosure List
 Canada aimed to align as closely
as possible to US, but there are
still differences
 3-Stage Transition
 1st deadline May 31, 2017
 Complete adoption by Dec. 1, 2018
Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
Links to HazCom 2012/ GHS Info
• MSDSonline GHS Answer Center
• http://www.msdsonline.com/blog/ghs-answer-center/
• MSDSonline GHS 101
• http://www.msdsonline.com/blog/ghs-101-links-touseful-ghs-information/
• OSHA HazCom Info Page
• https://www.osha.gov/dsg/hazcom/index.html
Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.
For Questions or
Presentation Copies:
Chuck Haling
chaling@msdsonline.com
Thank you!
1.888.362.2007
www.MSDSonline.com
ComplianceExpert@MSDSonline.com
Copyright © 2001-2015, MSDSonline®. All Rights Reserved. MSDSonline® is a proprietary trademark of MSDSonline. All other trademarks are the property of the respective owners.