Global Product Regulatory ARIZONA CHEMICAL COMPANY 1201 W. LATHROP AVENUE SAVANNAH, GA 31415 www.azchem.com OSHA GHS Frequently Asked Questions Q. Can you summarize what this announcement is about? A. In March of 2012, OSHA revised the Hazard Communication (HAZCOM) standard. The new HAZCOM standard adopts elements of the UN’s Global Harmonized System (GHS). Arizona Chemical will soon be shipping products with the new OSHA HAZCOM standard GHS labels and SDSs. Arizona Chemical wants customers to be aware that they will soon be seeing different SDSs and labels that are designed to comply with the new OSHA GHS HAZCOM standard. Q. Are Arizona Chemical products changing? A. No. The products that you receive with the new OSHA GHS labels and SDSs are the same products that you received prior to the change. There is no change to the chemistry, formulations, hazards, or performance of our products. The change is to how OSHA requires us to classify and label our products and how we communicate the hazards. Q. What is GHS? A. GHS stands for the “Globally Harmonized System” which is an international approach to hazard communication. It was developed by the United Nations (UN) and includes standardized classification criteria for the health, physical, and environmental hazards of chemical substances. GHS also has standard label elements including pictograms, signal words, hazard statements, and precautionary statements. In addition, the old OSHA Material Safety Data Sheet (MSDS) must now meet a standard format and content and be called a “Safety Data Sheet “ (SDS). Q. Will Arizona Chemical’s GHS labels look the same globally ? A. No. Some countries have chosen to adopt the UN GHS regulations as written and other countries have only adopted certain categories. In addition, some countries have included additional requirements or set different concentration limits for classification. In the U.S., OSHA SDSs and labels may look different from GHS labels for the same product intended for other countries due to differences with OSHA’s adoption and implementation of the standard. Q. When will we begin seeing the new OSHA GHS SDSs and labels from Arizona Chemical? A. Arizona will begin transitioning to new SDSs and labels in September 2014 and will have all products converted to the new OSHA GHS by the June 1, 2015, deadline. Q. Can we get some indication of the change in the products we buy before we start to receive the new SDSs and labels? A. Arizona Chemical has done a preliminary analysis of the changes expected and can provide that information on a case-bycase basis upon request by the customer. Please contact your Account Manager to obtain this information. Q What are some examples of the differences between OSHA GHS and other countries? A. OSHA regulates workplace safety and has authority over ensuring workers understand the hazards of chemicals that they use in the workplace. Therefore, OSHA has identified certain hazards that other countries currently do not recognize and regulate. One example is Combustible Dust. Even though a product may be non-hazardous by UN GHS criteria, if it is capable of producing a combustible dust in the workplace under foresseable conditions of use or emergency situations, the manufacturer must classify the product as “hazardous” under OSHA with “Combustible Dust” as a hazard, and provide the mandated combustible dust warnings. Products such as granulated sugar or cornstarch, which are normally considered nonhazardous, can and have produced combustible dust conditions, and are now considered by OSHA to be hazardous. Page 2 May 27, 2014 Other differences between OSHA GHS and UN GHS include, but are not limited to, the following: Pyrophoric gases – this is a hazard class recognized by OSHA but not by the UN for gases that catch fire spontaneously if exposed to air. Simple asphyxiants such as inert gases that can cause harm by displacing oxygen in a workers breathing air. OSHA does not have authority to regulate environmental hazards and therefore has not mandated use of the environmental classifications that exist under U.N. GHS. Use of the environmental hazards classification is voluntary in the U.S. Finally, OSHA has modified some of the classification thresholds such as the threshold for skin sensitizers. U.N. GHS requires products that contain a skin sensitizer to be classified as a skin sensitizer when the sensitizer is present at > 1.0%. OSHA regulations specify a threshold for certain skin sensitizers (Category 1a) ≥ 0.1%. Q. Can you explain more about combustible dust hazards? A. After several significant and deadly incidents involving combustible dusts, OSHA developed a program to educate employers and employees on the dangers of combustible dusts. In 2005, they issued a Guidance document on preventing and mitigating the effects of combustible dust fire and explosions. Several more guidance documents were published to help combat the explosion and fire hazards from combustible dust. OSHA created the new hazard classification for combustible dusts, so now any substance capable of creating a combustible dust in the workplace will be classified as OSHA hazardous. Many Arizona Chemical products that were classified as “Nonhazardous” under previous OSHA HAZCOM (HCS 1994) will now be classified as “OSHA Hazardous” because they have a remote possibility of forming a combustible dust in the workplace. For more information on combustible dusts please visit the OSHA webpage at: https://www.osha.gov/dsg/combustibledust/index.html Q. What about Environmental hazards and classification? A. OSHA controls workplace safety standards and therefore has no authority over Environmental matters, such as GHS environmental classification. Arizona Chemical is a strong believer in environment protection and stewardship. Therefore, we will provide environmental data that we have on our products in our SDSs. Because OSHA has not published environmental regulatory classification thresholds, Arizona Chemical will not classify for GHS environmental hazards on our US OSHA SDSs or labels. Q. What about consumer products? A. OSHA’s regulatory authority is limited to the workplace, so they have no authority over how consumer products are classified or the necessary warnings to the consumer. The Consumer Product Safety Commission (CPSC) has this authority over these. Regulations regarding chemicals for consumer use can be found in the Consumer Product Safety Act, the Federal Hazardous Substances Act, the Flammable Fabrics Act, and the Poison Prevention Packaging Act. The CPSC is considering adopting some portions of GHS for consumer labeling - particularly GHS Annex 5 regarding risk based labeling of consumer products. Q. Are any other Agency regulations changing due to GHS? A. In addition to the CPSC, other agencies such as the FDA, EPA, and DOT also reviewed the adoption of GHS as a potential for changes to their regulations. Currently, no changes are expected to FDA regulations. DOT regulations have changed over the past few years to reflect some of the GHS classification criteria and stay in harmony with UN Dangerous Goods regulations. Changes have been made to hazard classification criteria for flammable substances, toxic substances, and marine pollutants in the past few years. An example of how DOT and GHS are harmonized is given in the table below. Page 3 May 27, 2014 Flash Point (FP) /Boiling Point (BP) 0 0 FP < 23 C, BP < 35 C 0 0 FP < 23 C, BP >35 C 0 0 FP > 23 C and < 60 C 0 0 FP > 60 C and < 93 C GHS Flammable Liquid Classification Hazard Category 1 Hazard Category 2 Hazard Category 3 Hazard Category 4 DOT Flammable Liquid Classification Packing Group 1 Packing Group 2 Packing Group 3 Combustible Liquid As mentioned earlier, the environmental classification of products is not regulated on an SDS or label. The EPA has looked at adopting GHS, particularly for pesticide labeling. The adoption of GHS would require a complete economic and regulatory impact analysis, along with rule-making to change current pesticide labeling and classification regulations. The EPA is not prepared at this time to undertake these formidable tasks and has therefore not yet pursued adopting GHS. Q. What is the timeframe for the change to OSHA GHS? A. OSHA mandates that manufacturers must comply with the new OSHA GHS standard by June 1, 2015. Distributors have until December 1, 2015, to ensure all products they distribute are labeled under the new OSHA HAZCOM standard. We are currently in a transition period where manufacturers such as Arizona Chemical will begin transitioning to the new OSHA GHS labels and SDSs. The regulated time frame is as follows: Effective Completion Date December 1, 2013 June 1, 2015* Requirement(s) Train employees on the new label elements and SDS format. Comply with all modified provisions of this final rule, except: Who Employers Chemical manufacturers, importers, distributors and employers December 1, 2015 Distributors may ship products labeled by manufacturers under the old system until December 1, 2015. June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers Transition Period Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors and employers Q. Where can I find out more about the OSHA GHS HAZCOM standard? A. Please visit the OSHA webpage at: https://www.osha.gov/dsg/hazcom/index.html About Arizona Chemical Company Established in 1930, Arizona Chemical is the world’s leading biorefiner of pine chemicals. We provide natural pine-based materials to our customers in many diverse markets including adhesives, roads & construction, tires & rubber, lubricants, fuel additives, and mining. Since the beginning, we have been committed to making the world healthier, cleaner, safer and more efficient. We refine and upgrade Crude Tall Oil (CTO) and Crude Sulfate Turpentine (CST), both of which are co-products of the wood pulping process to produce paper. CTO and CST are sustainable and biodegradable raw materials that originate from the pine tree. Thanks to our state-of-the-art manufacturing practices, we are able to generate the highest value from Crude Tall Oil (CTO), a co-product of the paper making process, while optimizing energy efficiency and minimizing emissions and waste. All our manufacturing locations are accredited to high environmental standards.
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