SELLING IT, RETURN ON INVESTMENT, CHALLENGES AND IMPLEMENTATION PAUL ZEL ENVIRONMENTAL HEALTH & SAFETY MEMORIAL SLOAN-KETTERING CANCER CENTER OCTOBER 3, 2012
I know, it s mandatory. Sell it to management -- cost of implementation and use of resources = The Investment Recognize and emphasize the potential return on this investment. Get buy-in from employees.
Let s make it work!
What has not changed with Hazard Communication? Chemical hazards are classified This information is transmitted to employers and their employees Let us not forget the good things we have accomplished since 1983 with the original Haz Comm Standard!
What is new with Hazard Communication? We accept that there is always room for improvement. A harmonized chemical container labeling system Expectation for obtaining consistency in chemical safety information. How does the new Standard achieve this?
Chemical container labels Pictograms Signal words (Danger, Warning) Hazard statement Precautionary statement
Health Hazard Pictogram SIGNAL WORDS: DANGER Hazard statement: Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity WARNING
Skull and Crossbones Pictogram Hazard statement: Acute Toxicity (fatal or toxic) SIGNAL WORDS: DANGER WARNING
Corrosion Exploding Bomb Skin Corrosion/Burns Eye Damage Corrosive to Metals DANGER; WARNING Explosives Self-Reactives Organic Peroxides DANGER; WARNING
FLAME FLAME ON CIRCLE Flammables Pyrophorics Self-Heating Emits Flammable Gas Self-Reactives Organic Peroxides Oxidizers DANGER; WARNING DANGER; WARNING
GAS CYLINDER ENVIRONMENTAL (non-mandatory) Gases Under Pressure Aquatic Toxicity
Exclamation Mark Irritant (skin and eye) Skin Sensitizer Acute Toxicity Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (Non-Mandatory)
MATERIAL SAFETY DATA SHEET (MSDS) SAFETY DATA SHEETS (SDS)
Hazard Communication Safety Data Sheets Section 1: Identification Section 2: Hazard(s) identification Section 3: Composition/information on ingredients Section 4: First-aid measures Section 5: Fire-fighting Section 6: Accidental release measures Section 7: Handling and storage
Hazard Communication Safety Data Sheets 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 * = non-mandatory
COMPLETION DATE DEC. 1, 2013 JUNE 1, 2015 DEC. 1, 2015 JUNE 1, 2016 REQUIREMENT Train employees on new label elements and SDS format Compliance with all modified provisions of Haz Comm Standard Deadline for shipping containers without new GHS labels Update workplace Haz Comm and labeling programs; provide additional employee training for new physical or health hazards Employers WHO? Chemical manufacturers, distributors, importers, employers Chemical manufacturers, distributors, importers, employers All
TRAINING, TRAINING, TRAINING ADD TO EXISTING INITIAL AND REFRESHER HAZ COMM TRAINING PROGRAMS THE SELL TO MANAGEMENT AND THE EMPLOYEE: NOT JUST NEW REGULATIONS FOR THE SAKE OF REGULATING IMPROVE WORKER HEALTH AND SAFETY; OBTAIN AND PROVIDE BETTER KNOWLEDGE FOR HANDLING, STORING, DISPOSAL AND EMERGENCY RESPONSE RELATED TO HAZARDOUS CHEMICALS
COSTS BENEFITS
Using the 1% estimate, OSHA anticipates: Prevention of 318 more non-lost-workday injuries and illnesses Prevention of 203 lost-workday injuries and illnesses, 64 chronic illnesses, and 43 fatalities associated with chemical use These health and safety benefits have a value of $367 million annually (in 2010 dollars) Source: 29 CFR 1910.1200 Final Rule (2012)
Consistency of information on each Safety Data Sheet.
A 2 page MSDS!
9 sections of safety information
16 standardized sections. Some may even display the pictograms!
CONSISTENT INFORMATION TO A WIDE AUDIENCE Workers handling chemicals Emergency responders (spills) Fire fighters Industrial hygienists and other safety professionals Healthcare providers (treating chemical exposures and accidents)
Old labels vs. GHS labels
GHS Label Chemical name(s) Signal word Hazard and Precautionary statements Pictogram(s)
The psychology of pictograms High retention rate Value to employees with low or limited literacy Universal for employees where English is second language See them from a distance (emergency responders)
Influence of Signal Words Students rating consumer product labels with signal words perceived an increase in hazard compared to labels with their absence. * The signal word Danger was significantly more likely to influence worker behavioral intentions. ** * Wogalter, et. al. (1992); Haz Comm Std Document # 0300 ** Adams, et. al. (1998); Haz Comm Std Document # 0235
Small container labeling Secondary container labeling Lab employees who ship hazardous chemicals Cross reference to other OSHA standards (ie: formaldehyde, methylene chloride, HAZWOPER): edit your P&P s
Safety Data Sheets still difficult to understand. 39% of a large research lab facility with literate, trained workers who spoke English as their first language, expressed difficulty reading Material Safety Data Sheets * * Phillips (1997) Haz Comm Std Document # 0263)
Replace your Material Safety Data Sheet databases with Safety Data Sheets (SDS) If you use an online MSDS service, when will the site or vendor be making a transition to SDS s?
Although the U.S. Department of Transportation (DOT) and Environmental Protection Agency (EPA) are recognizing globalization...there will still be some label confusion.
Here is some trivia... Look at the pictogram format: GHS requires a solid red border How many people in the U.S. are red colorblind?
1 in 76 or 1.3% or 3.5 million people in the U.S. are green/red colorblind
Sell it to your institution s management for their support. Emphasize the value to your employees - It s not just about the regulations - Their health and safety are the true beneficiaries Keep your eyes open for vendor announcements on GHS label products OSHA s timetable for implementation is generous but start EARLY.
GHS enhances Hazard Communication Good Hazard Communication reduces risk of harm from physical and health dangers associated with chemicals A winning formula!