OSHA 2012 Revised Hazard
Communication Standard
USC Upstate OSHA Employee Training
September 2013
1
GHS
• On March 26, 2012 OSHA published the
final rule to align the OSHA Hazard
Communication Standard (HCS) with
the Globally Harmonized System of
Classification and Labeling of
Chemicals (GHS)
• The change will help ensure improved
quality and more consistency in the
classification and labeling of all
chemicals
2
GHS
• The benefits include enhanced worker comprehension
resulting in appropriate handling and use of
chemicals. The harmonized format of the safety data
sheets will enable workers to access the information
more efficiently
• Also currently multiple labels and safety data sheets
must often be developed by chemical manufacturers
for the same product when shipped overseas. This
creates a major compliance burden increasing costs
3
GHS
• The primary benefit of the GHS is that it provides a
single set of harmonized criteria for classifying
chemicals according to their health and physical
hazards and specifies hazard communication elements
for labeling and safety data sheets. Under the GHS
labels would include signal words, pictograms, and
hazard and precautionary statements and safety data
sheets would have a standardized format
4
GHS
• The major proposed changes to the HCS:
– Hazard Classification (changed from hazard
determination)
– Labels
– Safety Data Sheets (changed from materials safety data
sheets)
– Information and Training
• Will affect nearly 40 million workers and 5 million
workplaces
5
TLVs, PELs, & other exposure
limits
• TLVs, PELs, and “any other exposer limit
recommended by the chemical manufacturer,
importer or employer are required”
6
Carcinogenicity
• If a chemical is listed as carcinogen by IARC
or NTP, it must be noted on the SDS
• If OSHA finds a chemical to be a carcinogen,
it must be noted on the SDS
7
GHS
• It is estimated that implementing
the GHS will prevent 43
fatalities and 585 injuries and
illnesses annually
• The DOT has already modified
their requirements for
classification and labeling to be
consistent with UN transport
requirements and the GHS
8
Phase-In dates
Effective Completion
date
Requirements
Who
Dec 1, 2013
Train employees on new labels and Safety Data
Sheet format
Employers
June 1, 2015
Compliance with modified provisions of final
rule except:
December 1, 2015
Distributors shall not ship containers labeled
unless it is a GHS label
Chemical
manufacturers,
importers, distributors &
employers
Employers
June 1, 2016
Update workplace labeling and HAZCOM
program. Additional employee training on newly
found physical or health hazards
Transition period
May comply with final HAZCOM std. or current
std., or both
Chemical
manufacturers,
importers, distributors &
employers
9
GHS Hazard Classification
• The list of chemicals presenting a ‘Health’ hazard
was deleted from the current HCS and the proposed
HCS has identified a new listing
• A ‘Health Hazard’ means a chemical which is
classified as posing one of the following hazardous
effects:
10
GHS Hazard Classification
–
–
–
–
–
–
–
–
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)
– Aspiration Hazard
11
GHS Hazard Classification
• The list of chemicals presenting a ‘Physical’ hazard
was deleted from the current HCS and the proposed
HCS has identified a new listing
• A ‘Physical Hazard’ means a chemical that is
classified as posing one of the following hazardous
effects:
12
GHS Hazard Classification
–
–
–
–
–
–
–
–
–
–
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
Contact With Water Emits Flammable Gas
13
GHS Hazard Classification
• The HCS does not address environmental hazards and
OSHA does not have jurisdiction over that. There are
environmental hazard classifications:
– Hazardous to the Aquatic Environment
• Acute Aquatic Toxicity
• Chronic Aquatic Toxicity
– Bioaccumulation Potential
– Rapid Degradability
14
OSHA Hazard Classification
• In OSHA’s proposed rule there was a hazard category
called ‘Unclassified’ which is not in the UN GHS
system
– … a chemical for which there is scientific evidence identified
during the classification process that may pose an adverse
physical or health effect when present in a workplace under
normal conditions of use or in a foreseeable emergency, but
the evidence does not currently meet specified criteria for
physical or health hazard classification in this section. This
does not include adverse physical or health effects for which
there is a hazard class addressed in this section
– Example: Combustible Dust
15
Hazards Not otherwise Classified
• OSHA changed “unclassified hazards” to
“hazards not otherwise classified” (HNOC)
• For issues that have not gone through a
rulemaking
• Combustible dust is considered “hazardous
chemical”
16
Hazardous Chemical
• OSHA classified as Hazardous Chemicals:
– Pyrophoric gases, signal word “danger”, “catches
fire spontaneously if exposed to air”*
– Simple asphyxiants, signal word “warning”, “may
displace oxygen and cause rapid suffocation”*
– Combustible dust, signal word “warning”, “May
form combustible dust concentrations in the air”*
*Hazard Statements
17
National Chamber of Commerce Concerns
Marc Freedman, executive director of labor law for
NCOC:
• “OSHA went too far by requiring labels to include
hazard information about combustible dust”
• “It’s going to create a lot confusion and uncertainty,
which will undermine whatever other value this
regulation provides to these companies.” Source:
Associated Press, March 20, 2012
18
Combustible Dust
• “The fact is that combustible dust has been destroying
workplaces and killing or injuring workers for many years. By
including combustible dust in Safety Data Sheets employers
will save money by not having to have the dust analyzed at
their expense and preventing fires and explosions in their
workplaces.”
– Source: EHS Today, March 21, 2012
19
GHS Labels
• Three standardized GHS label elements:
– Symbols (Hazard Pictograms) that convey health,
physical, and environmental hazard information
assigned to a GHS hazard class and category
– Signal Words “Danger” or “Warning” used to
emphasize hazards and relative level of severity of the
hazard and assigned to a GHS hazard class and
category
– Hazard Statements which are standard phrases
assigned to a hazard class and category that describe
the nature of the hazard
20
GHS Labels
• Key Elements
–
–
–
–
–
–
–
Product Identifier
Supplier Identifier
Chemical Identity
Hazard Pictograms*
Signal Words*
Hazard Statements*
Precautionary
Information
* Standardized
21
GHS Labels
Red
border
GHS
-----Black
border
Transport
22
GHS Labels
Hazard Classes may have ‘Categories’
23
GHS Labels
24
GHS Labels
Example of a Transportation and GHS label combined
25
Safety Data Sheets (SDS)
• The OSHA ‘Material Safety Data Sheet’ (MSDS)
will be called a ‘Safety Data Sheet’ (SDS)
• The MSDS has 8 non-mandatory sections
• The SDS would have 12 mandatory and 4 nonmandatory sections and is essentially the ANSI
Z400.1-2004 format
– Sections 12-15 are not mandatory and cover
Ecological, Disposal, Transport, and Regulatory
information
26
Safety Data Sheets (SDS)
27
HCS 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
28
GHS Changes in the Future
• The GHS is updated as needed to reflect new
technology and scientific developments, or provide
explanatory text. Changes to the HCS is anticipated
through:
– Technical Updates for minor terminology changes
– Direct Final Rules for text clarification
– Notice and Comment Rulemaking for more
substantive or controversial updates such as additional
or changes in health or safety hazard classes or
categories
29
Resources
• On the OSHA website
under ‘Safety and
Health Topics’ there is a
Hazard Communication
webpage with many
resources and
documents including a
link to a GHS page
30
Resources
• The GHS webpage has
lots of documents
including side by side
comparisons of the HCS
and the new proposed
HCS
31
Resources
• OSHA published ‘A
Guide to The Globally
Harmonized System of
Classification and
Labeling of Chemicals
(GHS)
• It can be downloaded
from the OSHA website
32
Disclaimer
•
This information has been developed by an OSHA Compliance Assistance
Specialist and is intended to assist employers, workers, and others as they strive to
improve workplace health and safety. While we attempt to thoroughly address
specific topics [or hazards], it is not possible to include discussion of everything
necessary to ensure a healthy and safe working environment in a presentation of
this nature. Thus, this information must be understood as a tool for addressing
workplace hazards, rather than an exhaustive statement of an employer’s legal
obligations, which are defined by statute, regulations, and standards. Likewise, to
the extent that this information references practices or procedures that may enhance
health or safety, but which are not required by a statute, regulation, or standard, it
cannot, and does not, create additional legal obligations. Finally, over time, OSHA
may modify rules and interpretations in light of new technology, information, or
circumstances; to keep apprised of such developments, or to review information on
a wide range of occupational safety and health topics, you can visit OSHA’s
website at www.osha.gov.
33
You may now finish this safety training tutorial
by completing the OSHA Assessment Quiz.
34