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Safety Check: OSHA’s New Hazard Communication System; Are You Ready?
HazCom: As the world works to standardize chemical hazard communications, OSHA is updating its requirements and labeling policies. Are you ready to comply?
By Jary Winstead
Date Posted: 10/1/2013
Many countries around the world have either already adopted or have started transitioning to the new United Nation’s Globally Harmonized System (GHS), which is also called the Purple Book. The new hazard communication system is meant to standardize chemical hazard identification and information around the globe. In the United States alone, we use or produce over 575,000 different chemicals, and with the GHS, both imported and exported chemical labeling and information will be standardized.
The Occupational Safety and Health Administration (OSHA) Standard 1910.1200, the Hazard Communication Standard (HCS), requires chemical manufacturers, importers, and distributors to classify the hazards of their chemical products and to provide that information in the form of labels and safety data sheets to users of the products.
Starting this year U.S. companies need to train their employees on the new Hazard Communication and Chemical Safety System, the GHS. This will certainly have an effect on the wood products industry in regards to the training that must be provided and the information used to track hazardous chemicals at facilities. The GHS will have no effect on the chemicals, just the organization of the chemical’s information and the labeling. Will it take a lot of time or money? I don’t think so, other than the time it takes to update employee training and the Safety Data Sheet booklets.
According to OSHA, the GHS is a system for standardizing and harmonizing the classification and labeling of chemicals.
It is a logical and comprehensive approach to:
• Defining health, physical and environmental hazards of chemicals;
• Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria; and
• Communicating hazard information, as well as protective measures, on labels and Safety Data Sheets (SDS).
According to OSHA, the three major areas of change are in hazard classification, labels and SDS.
• Hazard classification: 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 as a result.
• Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
• Safety Data Sheets: Will now have a specified 16-section format.
The new GHS breaks down the chemical hazards to the following types of health, environmental and physical hazards:
Chemicals are health hazards when they are classified as posing one of these hazardous effects: acute toxicity (any route of exposure), aspiration toxicity, carcinogenicity, germ cell mutagenicity, reproductive toxicity, respiratory or skin sensitization, serious eye damage or eye irritation, skin corrosion and irritation, or specific target organ toxicity (single or repeated exposure). Health effects can range from acute effects (symptoms of short-duration or that appear immediately after an exposure) to chronic conditions.
Hazardous to the aquatic environment this includes acute and chronic aquatic toxicity.
There are numerous potential physical hazards including: explosives, flammable gases, flammable aerosols, oxidizing gases, gases under pressure, flammable liquids, flammable solids, self-reactive substances, pyrophoric liquids, pyrophoric solids, self-heating substances, substances which in contact with water emit flammable gases, oxidizing liquids, oxidizing solids, organic peroxides or corrosive to metals.
GHS Labeling Changes
The GHS will be requiring changes to the warning labels, placards and pictographs that people see on the chemicals used every day.
In accordance to the new OSHA standard, labels will require the following elements:
• Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under OSHA’s HCS.
• Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for less severe hazards.
• Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
• Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical.
GHS changes to Safety Data Sheets
U.S. industry has been using the Material Safety Data Sheet (MSDS) for many years, and with the new GHS, I see very little in the way of changes. The sections found on the current MSDS are nearly the same as the new SDS. The difference is that manufacturers must use the following standardized format for the 16 sections:
• Section 1. Identification
• Section 2. Hazard(s) identification
• Section 3. Composition/information on ingredients
• Section 4. First-aid measures
• Section 5. Fire-fighting measures
• Section 6. Accidental release measures
• Section 7. Handling and storage
• Section 8. Exposure controls/personal protection
• Section 9. Physical and chemical properties
• Section 10. Stability and reactivity
• Section 11. Toxicological information
• Section 12. Ecological information
• Section 13. Disposal considerations
• Section 14. Transport information
• Section 15. Regulatory information
• Section 16. Other information, including date of preparation or last revision
What are the benefits? By standardizing the information, the intention is to make it easier to understand the information found on chemical labels, warning and hazard signs, and the SDS. The intended benefits to companies include fostering a safer work environment and improved relations with employees, increasing efficiency and reducing costs from compliance with hazard communication regulations, facilitating electronic transmission systems with international scope, and expanding the use of training programs on health and safety. The revised labeling initiative should also over time reduce costs due to fewer accidents and illnesses.
The intended benefits to workers and members of the public include improved safety for workers and others through consistent and simplified communications on chemical as well as greater awareness of hazards, resulting in safer use of chemicals in the workplace and in the home.
GHS Compliance Dates
Table 1 provides the effective completion dates for the GHS compliance requirements.
OSHA training requirement details can be found online via this link to the OSHA fact sheet: https://www.osha.gov/Publications/OSHA3642.pdf
There is also a helpful side-by-side comparison that can be found online at this OSHA link https://www.osha.gov/dsg/hazcom/side-by-side.html
OSHA’s Hazard Communication website (http://www.osha.gov/dsg/hazcom/index.html) has the following QuickCards and OSHA Briefs to assist employers with the required training.
• Label QuickCard (English/Spanish)
• Pictogram QuickCard (English/Spanish)
• Safety Data Sheet QuickCard (English) (Spanish)
• Safety Data Sheet OSHA Brief
• Label/Pictogram OSHA Brief
Editor’s Note: Jary Winstead is a safety consultant, author and trainer who serves a variety of industries including the forest products sector. He owns Work Safety Services LLC and can be reached at SAFEJARY@aol.com.