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GLOBALLY HARMONIZED SYSTEM for HAZARD COMMUNICATION

David Wallace, CIH Sr. Lecturer, Utah State University


Nevada Local Section, AIHA March 9, 2011

Outline
GHS overview OSHAs GHS activity Proposed changes to the Hazard Communication Standard Current status of the proposed standard Impact on Safety professionals
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Introduction
In 1985, one of my jobs as a young industrial hygiene professional was helping my employer comply with OSHAs new Hazard Communication standard, 1910.1200. Now, it looks like we will need to do it again!
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Introduction
AIHA online GHS course, if you want to learn more!

GHS Overview
Globally Harmonized System Of Classification And Labeling Of Chemicals
United Nations guidance for a uniform (harmonized) hazard communication system
Initiated at the 1992 United Nations Conference on Environment and Development (UNCED)

Based on major existing systems


USA and Canadian systems for the workplace, workplace, consumers and pesticides European Union directives for classification and labeling of substances and preparations United Nations Recommendations on the Transport of Dangerous Goods.

GHS Overview
Elements
Harmonized criteria for classifying substances and mixtures according to their health, environmental and physical hazards Harmonized hazard communication elements, including requirements for labeling and safety data sheets.
Guide to the GHS (OSHA)
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GHS Purple Book

GHS Overview
Justification
Label requirements differ, requiring multiple labels for the same product Hazard definitions are not consistent
Toxicity, Flammability

Globally over 100 diverse hazard communication regulations for their products globally
Regulatory compliance is complex and costly Barrier to international trade in chemicals
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Flammability example

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Flammability Example
OSHA letter of interpretation, July 14, 2010
Re: The definitions of combustible and flammable liquids under 29 CFR 1926 and 29 CFR 1910. Question: Why are the definitions for combustible liquids and flammable liquids different under OSHA's construction and general industry standards? Answer: The definitions in the two standards are different because the definitions were adopted from different sources. OSHA is currently addressing these definitions in the Hazard Communication rulemaking. [GHS} http://www.osha.gov/pls/oshaweb/owadisp.show_document? p_table=INTERPRETATIONS&p_id=27488
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GHS Overview
Key Guiding Principles of the Harmonization Process
Protection will not be reduced Will be based on intrinsic properties (hazards) of chemicals All types of chemicals will be covered All systems will have to be changed Involvement of all stakeholders should be ensured Comprehensibility must be addressed
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GHS Hazard Classification


Defined criteria are used to assign a hazard classification
Physical Hazards
16 categories

Health Hazards
10 categories

Environmental Hazards

Mixtures
GHS classification guidance for when chemicals are mixed
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GHS Hazard Classification


Physical Hazards (16)
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 Corrosive to Metals

GHS Hazard Classification


Health Hazards (10)
Acute Toxicity Skin Corrosion/Irritation Serous Eye Damage/Eye Irritation Respiratory or Skin Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicology Target Organ Systemic Toxicity Single Exposure Target Organ Systemic Toxicity Repeated Exposure Aspiration Toxicity
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GHS Hazard Classification


Hazardous to the Aquatic Environment
Acute aquatic toxicity Chronic aquatic toxicity
Bioaccumulation potential Rapid degradability

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GHS Hazard Communication


Labels
Symbols (hazard pictograms) with red border
Examples:

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GHS Hazard Communication


Labels (cont.)
Nine symbols
Includes Environment

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GHS Hazard Communication


Labels (cont.)
Signal Words
Danger or Warning

Hazard Statements
Example: Toxic if swallowed

Other
Precautions, identification, supplier, supplemental

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GHS Hazard Communication


Labels (cont.)
GHS Label Elements for Flammable Liquids

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GHS label example

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GHS Hazard Communication


GHS Safety Data Sheet (SDS)
16 headings Similar to ISO, EU, and ANSI MSDS/SDS requirements

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OSHA MSDS format (old)


OSHA-174 (1989), 8 sections (nonmandatory)
1. 2. 3. 4. 5. 6. 7. 8. Manufacturer information Hazard Ingredients/Identity Information Physical/chemical properties Fire and Explosion Hazard Data Reactivity Data Health Hazard Data Precautions for Safe Handling and Use Control Measures
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ANSI MSDS format


ANSI Z400.1-2004
1. Product and Company Identification 2. Hazard Identification 3. Composition / Information On Ingredients 4. First Aid Measures 5. Fire Fighting Measures 6. Accidental Release Measures 7. Handling and Storage 8. Exposure Control / Personal Protection 9. Physical and Chemical Properties 10. Stability and Reactivity 11. Toxicological Information 12. Ecological Information 13. Disposal Considerations 14. Transport Information 15. Regulatory Information 16. Other Information
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OSHA and the GHS


Rulemaking Steps
Sept. 12, 2006

Advance Notice of Proposed Rulemaking, ANPR

Notice of Proposed Rulemaking

Final Standard

Sept. 30, 2009 Public Comment Period ended Dec. 29, 2009 Public Hearings Washington, Pittsburgh and Los Angeles March and April, 2010 Post-hearing Comment Period ended June 1, 2010 Probably by late 2011, according to OSHA staff
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Phase-in Period for Compliance


2-3 years (as proposed)

Proposed OSHA rule

Major changes to the Hazard Communication Standards


Changed hazard determination to hazard classification Changed MSDS to SDS Changed definitions to comply with GHS Labels for shipped containers must have GHS information Workplace labels may be GHS labels, or other labels that identify the material and hazard Safety Data Sheets with 16 sections May include guidance for transportation information and environmental hazards 27
Side-by-side comparison (OSHA)

Proposed OSHA rule


Major changes to the Hazard Communication Standards (cont.) Other OSHA standards are changed where applicable
New wording on warning signs for asbestos and other health hazards Changes to standards for HAZWOPER, Combustible and Flammable Liquids, Welding Cutting and Brazing, etc.
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Proposed OSHA rule


Effective dates
Two years after final rule
Employee training on new labels and safety data sheets

Three years after final rule


Chemical manufacturers, importers, distributors, and employers in compliance with all modified provisions

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Proposed OSHA rule


Costs and benefits
$97 million annual cost
training, SDSs & labels, management

$851 million annual benefit


reduced injuries/illnesses/fatalities, improved productivity and cost reduction

$754 million net annual benefit

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OSHA interpretation
GHS labels comply with current OSHA requirements
Standard Interpretation 10/06/2009 - Using the Globally Harmonized System (GHS) to Comply with OSHA's Hazard Communication Standard http://www.osha.gov/pls/oshaweb/owadisp. show_document?p_table=INTERPRETATI ONS&p_id=27218
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Comments on the proposed rule


OSHA specifically solicited comments about:
Costs and benefits Effect on small entities GHS classification system Combustible dusts and simple asphyxiants Color labels vs. B&W PELs on data sheets Etc.

Public Hearings ended April 13, 2010 Record closed June 1, 2010 (877 items)

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Comments on the proposed rule


Maureen Ruskin, director of OSHA's Office of Chemical Hazards, at GHS Round Table, 5/24/2010, AIHCE, Denver, Co
Vast majority of comments support OSHA OSHA should adopt EU reporting limits for chronic hazards Create hazards not otherwise classified category Support and criticism of proposal to drop TLVs Updating labels within 30 days may not be feasible OSHA may have underestimated cost of red border Mixed support for adoption of GHS hazard statements Disagreement about implementation dates OSHA should provide more information for training 33

Comments on the proposed rule


OSHAs update (cont.)
Some believe OSHA will create confusion with changes to flammable/combustible liquid classification, yet others agreed with OSHA OSHA should review safety standards to avoid conflicts Concerns over carcinogen notation changes in the health standards Concerns about conflict or confusion regarding EPA/DOT/NFPA OSHA underestimated costs Very little support for OSHAs proposed alternatives How will OSHA respond after UN updates GHS?
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ASSEs comment
ASSE applauds OSHA for its leadership in undertaking this rulemaking and urges that every possible step be taken to achieve a final rule as soon as practicable. However, ASSE has some concerns:

OSHA should include control banding OSHA underestimated the impact on small business Some hazard classifications should be modified OSHA should require red borders on labels Labels should have more required information TLV and REL exposure limits should be listed on data sheets The new standard should have a shorter deadline for training There may be a shortage of SH&E professional on staff 35 Etc.

AIHAs comment
AIHA supports the proposed revision of the HCS and believes it will result in better hazard recognition and safer use of chemicals in the workplace. AIHAs generally supports OSHA:

AIHA also submitted a post-hearing comment, April 29, 2010 to answer OSHA questions
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Proposed hazard classifications are OK OSHA should require red borders on labels TLVs , WEELs and other exposure limits should be listed on data sheets OSHA should include a hazard category for combustible dust Training should not be delayed

OSHAs Schedule
Record closed June 1 Tasks:
Analyze information in the record Prepare the final rule and update the analyses of the record Submit rule for administrative review OSHA, DOL, OMB

This is high priority for OSHA


Expect final standard about 1 years (?)
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Recent GHS activity


United Nations Subcommittee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (UNSCEGHS), Dec. 7-9, 2010, in Geneva OSHA hosted an open informal public meeting of the U.S. Interagency GHS Coordinating Group, Nov. 20, 2010.
To provide interested parties with an update on GHS issues in preparation for the UN meeting
http://www.osha.gov/pls/oshaweb/owadisp.show_document? 38 p_table=FEDERAL_REGISTER&p_id=21809

OSHAs Schedule
Dr. David Michaels, Assistant Secretary of Labor for OSHA
June 16, 2010 at the Baltimore ASSE conference:

the Global Harmonized System standard a non-controversial rule has received good comments and is moving along on target
Source: Occupational Health and Safety online magazine
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OSHAs Fall 2010 Regulatory Agenda, http://www.dol.gov/osha/regs/unifiedagenda/fall2010/1 218-AC20.htm


Timetable: Action ANPRM ANPRM Comment Period End Complete Peer Review of Economic Analysis NPRM NPRM Comment Period End Hearing Hearing Post Hearing Comment Period End Final Action Date 09/12/2006 11/13/2006 11/19/2007 09/30/2009 12/29/2009 03/02/2010 03/31/2010 06/01/2010 08/00/2011
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FR Cite 71 FR 53617

74 FR 50279

Commercial GHS services


Commercial Hazard Communication and MSDS/SDS authoring services should be ready for GHS
Required for international trade Preparing for domestic market

Examples:
http://3ecompany.com/solutions/ghs-solutions/ http://www.sitehawk.com/ghs_home.html
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GHS in the commercial news


Industry Week
How to Convert to the Globally Harmonized System of Chemical Classification

EHS Today
GHS: The Power of One

OH&S
Major GHS Progress This Year

OSHA's GHS Leader Sees Final Rule in 18 Months Global Harmonization A Catalyst for Safety OSHA, GHS, and Your MSDSs and Labels A Picture is Worth a Thousand Words OSHA Finally Brings GHS to America

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Impact on Safety and IH Professionals


Become familiar with the new system
May want to wait until the OSHA rule is final

Collect new SDSs as provided by suppliers and incorporate them into the existing MSDS system (or use a commercial service) Get new GHS labels for shipped containers
Employers can use other systems for workplace labeling

Train employees about new labels and SDS


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Impact on Chemical Manufacturers and Distributors


Prepare and use new GHS compatible labels Prepare and distribute new GHS compatible Safety Data Sheets Commercial authoring firms are ready and willing to help

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GHS Resources
GHS Websites
OSHA, http://www.osha.gov/dsg/hazcom/global.html EPA, http://www.epa.gov/oppfead1/international/globalharmon.htm DOT http://www.phmsa.dot.gov/hazmat/regs/international CSPC, http://www.cpsc.gov/phth/GHSpolicy.html UN, http://www.unece.org/trans/danger/publi/ghs/ghs_rev02/02file s_e.html

Government Printing Office OSHA comments

http://www.gpoaccess.gov/ [this site will be replaced with the Federal Digital System, http://www.gpo.gov/fdsys/]
Docket No. OSHA-H022K- 2006-0062 at http://www.regulations.gov
Nearly 900 items!

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