Professional Documents
Culture Documents
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)
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 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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Health Hazards
10 categories
Environmental Hazards
Mixtures
GHS classification guidance for when chemicals are mixed
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Hazard Statements
Example: Toxic if swallowed
Other
Precautions, identification, supplier, supplemental
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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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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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Public Hearings ended April 13, 2010 Record closed June 1, 2010 (877 items)
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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
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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FR Cite 71 FR 53617
74 FR 50279
Examples:
http://3ecompany.com/solutions/ghs-solutions/ http://www.sitehawk.com/ghs_home.html
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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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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
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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
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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