Hazard Communication: What’s Required on December 1, 2013? October 2013 Presented by Lockton Companies Lockton Companies, LLC makes no representation or warranty nor assumes any responsibility that locations, products, work places operations, procedures, machinery or equipment of the Company are or will be safe or healthful or in compliance with any law, rule or regulation. L O C K T O N C O M P A N I E S Hazard Communication HAZARD COMMUNICATION: WHAT’S REQUIRED BY DECEMBER 1, 2013? In March 2012, the United States Occupational Safety & Health Administration (OSHA) revised the Hazard Communication Standard to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals. Two major changes in the revised standard require employers to use a new labeling protocol for chemicals used in the workplace and to follow a standardized format for communicating chemical hazards and characteristics on Safety Data Sheets. Employers are required to train workers on the new labeling and Safety Data Sheet format by December 1, 2013. The remaining requirements of the revised standard are phased in stages through June 1, 2016. Information employers must train employees in by December 1, 2013, is summarized below. For questions or additional information, please contact your Lockton Loss Control Specialist. Because of the dangers presented by hazardous chemicals, OSHA developed the Hazard Communication Standard (HCS), 29 CFR 1910.1200, in 1983. The standard is sometimes referred to as “HazCom” or the “right to know law”, requires employers to communicate the hazards of workplace chemicals to employees. The Hazard Communication Standard is available at https://www.osha.gov/pls/oshaweb/ owadisp.show_document?p_table=STANDARDS&p_id=10099. Recent changes in the Hazard Communication Standard have brought the regulation more in line with international standards with the implementation of the Globally Harmonized System of Classification and Labeling of Chemicals, or GHS for short. Created by the international community and adopted by the United Nations, the Globally Harmonized System provides a single set of criteria for classifying chemicals and mixtures according to their health, physical and environmental hazards. The OSHA HazCom standard says workers have a right to know the hazards of chemicals they work with or around in the workplace. Implementing GHS is intended to improve quality and consistency in the classification and labeling of all chemicals, helping an employee obtain and understand quickly critical safety information. GHS standardizes the following: Criteria for determining what hazardous effects a chemical poses, Chemical label elements assigned by hazard class and category, and Safety Data Sheets (SDS) so that employers, workers, health professionals, and emergency responders can access the information more efficiently. Hazard Communication Definitions of Chemical Hazards The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate. There are now two categories of hazards used: Physical hazards are the properties of a gas, liquid or solid that could adversely affect employees or the workplace in a physical way, such as a fire or explosion. Health hazards are determined by the properties of a substance or mixture that can cause illness or injury to the skin, eyes, lungs or other organs and body parts. Within these two broad categories of chemical hazards, OSHA has created 16 classes of physical hazards and 10 classes of health hazards. The 16 classes of physical hazards include explosives, flammable gases, aerosols, oxidizing gases, gases under pressure, flammable liquids, flammable solids and self-reactive substances and mixtures, and several others. The 10 classes of health hazards include acute toxicity, skin corrosion and irritation, serious eye damage or eye irritation, respiratory or skin sensitization. Chemical Label Format Beginning in June 2015, all labels will be required to include pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification. These labels provide information to ensure proper storage of hazardous chemicals, and to quickly locate information on first aid when needed by employees or emergency personnel: Product Identifier: This section will describe how the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS (Identification). Signal Word: Are used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. There are only two signal words, “Danger” and “Warning.” Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. There will only be one signal word on the label no matter how many hazards a chemical may have. If one of the hazards warrants a “Danger” signal word and another warrants the signal word “Warning,” then only “Danger” should appear on the label. Pictogram: Pictograms are standardized graphics, sometimes called harmonized hazard symbols, which are assigned to a specific hazard class or category. Pictograms on a GHS label may convey health, physical or environmental hazard information. Each pictogram is assigned to only one class of hazard. Hazard Statement(s): These describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.” All of the applicable hazard statements must appear on the label. Hazard Hazard Communication statements may be combined where appropriate to reduce redundancies and improve readability. The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it. Precautionary statement(s): Are phrases that describe recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling. Name, Address and Phone Number of the Chemical Manufacturer, Distributor, or Importer: This section provides information on whom the employee, employer, medical personnel or other concerned parties should contact with questions, or in case of emergency, regarding the chemical. Pictograms In addition to the label format, chemicals will have to be labeled with a “pictogram,” a sign indicating what hazards are associated with a chemical in the workplace. There are 9 pictograms in the revised Hazard Communication standard that are used to convey health, physical and environmental hazards. Health Hazard chemicals pose a risk to health if used improperly. This pictogram is also used when a substance can cause specific target organ toxicity following a single or repeated exposure. The Skull and Crossbones pictogram is used when a chemical is acutely toxic to the skin, lungs, or digestive system. The Exclamation Mark pictogram will be used in combination with a Health Hazard pictogram to signify particular health risks which are less severe than the Skull and Crossbones category. The Flame pictogram indicates there is a fire risk. The Flame Over Circle, or oxidizer pictogram, appears on a label when a chemical is an oxidizing gas, liquid or solid. The Corrosion label indicates a material is corrosive and should prompt awareness of personal protective equipment and storage requirements. Chemicals marked with an Exploding Bomb signify a material as explosive or unstable explosive organic peroxide. These chemicals pose a significant physical risk and should be treated with extreme caution. The Gas Cylinder pictogram alerts of the physical hazards inherent in the use and storage of compressed gases. Hazard Communication The Environment pictogram is a non-mandatory category for safety training purposes. Environmental hazards are not regulated by OSHA. All containers of hazardous chemicals must be labeled with the original label, or with the product identifier, words pictures or symbols to provide general information on the hazards. The hazard classification system must be consistent with GHS. The only exception to this labeling requirement is for “secondary containers.” A secondary container is a portable container of a chemical that has been transferred into that container by the employee who will use the chemical during his or her shift. The chemical must be used only by that employee, and no others, during a single work shift. Secondary containers are not required to be labeled. Safety Data Sheets Required by OSHA’s original Hazard Communication Standard, Material Safety Data Sheets have been the comprehensive source of safety information for employees, employers, emergency personnel, and medical providers. As part of the GHS, they are now called Safety Data Sheets and have a uniform format that allows employees to obtain concise, relevant and accurate information more easily. SDS’s will have the following 16 sections, in the order listed, to help workers know which section will provide needed information: Section 1 — Identification includes the product name and use, the manufacturer and a number to call in case of emergency. Section 2 — Hazard(s) Identification includes all hazards regarding the chemical. Section 3 — Composition/Information on ingredients includes information on chemical ingredients and any trade secret claims the manufacturer or supplier may have. Section 4 — First Aid Measures including important symptoms and effects, as well as required treatment. Section 5 — Fire-fighting Measures lists suitable extinguishing techniques, equipment needed and chemical hazards from fire. Section 6 — Accidental Release Measures to take in event of chemical release covering emergency procedures, protective equipment and proper methods of containment/clean-up. Section 7 — Handling and Storage lists precautions for safe handling and storage, including incompatibilities. Section 8 — Exposure Controls/Personal Protection lists OSHA’s Permissible Exposure Limits (PEL) and American Conference of Governmental Industrial Hygienists’(ACGIH) Threshold Limit Values (TLV) plus information on appropriate engineering controls and personal protective equipment (PPE) requirements. Section 9 — Physical and Chemical Properties lists the chemical’s characteristics. Hazard Communication Section 10 — Stability and Reactivity provides information on the chemical’s stability and possibility of hazardous reactions. Section 11 — Toxicological Information including routes of exposure, related symptoms, acute and chronic effects and numerical measures of toxicity. Section 12 — Ecological Information* Section 13 — Disposal Considerations* Section 14 — Transport Information* Section 15 — Regulatory Information* (*Note: Since other Agencies regulate this information, OSHA does not enforce Sections 12 through 15) Section 16 — Other Information, includes the date of preparation or last revision. Employers must ensure that SDSs are readily accessible to employees. Many establishments keep binders of current Safety Data Sheets in the appropriate departments. Chemical suppliers are required to provide employers with up-to-date SDS’s. Phase In-Dates The phase-in dates of the revised Hazard Communication are listed below: Required Completion Date Requirements Party Responsible December 1, 2013 Train employees on the new label elements and Safety Data Sheet (SDS) format. Employers June 1, 2015 Compliance with all modified provisions of the revised Hazard Communication Standard, except chemical manufacturers and distributors are still permitted to ship containers of chemicals that have labels acceptable under the original standard. Chemical Manufacturers and Distributers, Importers and Employers December 1, 2015 Chemical manufacturers/distributors must ensure that shipped containers of chemicals have labels that meet the requirements of the revised Hazard Communication Standard. Chemical Manufacturers and Distributers, Importers and Employers