GHS the United Nations Globally Harmonized System of Classification & Labeling of Chemicals GHS is a set of guidelines, not a regulation 2
GHS is designed to provide a consistent approach for globally classifying and communicating chemical hazards Harmonization from country to country and sector to sector (consumer, transport and workplace) Intended to improve workplace safety and reduce international trade barriers OSHA Hazard Communication Standard (HCS) alignment with GHS Referred to as HazCom 2012 Most significant changes are to Hazard Classification Criteria and Hazard Communication 3
Physical Hazards and Health & Environmental Hazards Most hazard categories are now subdivided into additional categories to indicate degree of severity of effect Example: Carcinogenicity Current HCS a product is classified Carcinogen New Hazcom: Carcinogenicity is further defined: Category 1: 1A Known, 1B Probable Category 2: Suspected 4
Material Safety Data Sheets (MSDS) now Safety Data Sheets (SDS) Standardized 16-part format (similar to ANSI) Section 2: Hazard(s) Identification Includes GHS Classification, Signal Word(s), Hazard Statement, Precautionary Statement Updated labels Information standardized under GHS and HCS Contains information from Section 2 of SDS Includes hazard pictograms Secondary labels must also be GHS compliant 5
http://www.osha.gov/publications/hazcomm_quickcard_pictogram.html 6
Note New: Hazard Pictograms, Signal Word and Hazard Statement 2013 Shepard http://www.osha.gov/publications/hazcomm_quickcard_labels.html Bros., Inc. 7
Chemical Manufacturers Evaluate and classify chemical hazards Prepare GHS-compliant safety data sheets and labels; supply to customers Importers & Distributors Provide safety data sheets and labels to customers Employers Who Use Chemicals Must have safety data sheets and labels for their exposed workers Provide training on proper chemical handling Written hazard communication plan 8
Effective Completion Date December 1, 2013 June 1,2015* December 1, 2015 June 1, 2016 Transition Period to the effective completion dates noted above Requirement(s) Train employees on the new label elements and safety data sheet (SDS) format Manufacturers & distributors complete reclassification and produce SDS/Label updates *Distributors may ship inventory with old SDS/Label until 12/1/2015 Full compliance with the final standard (29 CFR 1910.1200) May comply with either the final HazCom standard, or the current standard, or both Who Employers Chemical manufacturers, importers, distributors and employers Employers Chemical manufacturers, importers, distributors and employers Adapted from: http://www.osha.gov/dsg/hazcom/effectivedates.html 9
An OSHA violation is serious if death or serious physical harm can result from a hazard an employer knew or should have known exists HCS violations are #3 in OSHA s Top 10 List of most frequently cited compliance violations 2009-2011: OSHA cited over 20,000 HCS violations in U.S. workplaces Non-compliance can lead to real costs: Fines Downtime Potential risk & liability Lost revenues Negative press 10
Headline: OSHA fines Wisconsin Polishing and Plating more than $75,000 in penalties Company cited for failing to: Provide proper protective equipment for employees Develop or implement a hazard communication program Maintain material safety data information Inform employees of their right to access medical or exposure information and records Company given a rare willful citation for allowing an employee to be exposed to chromium VI above the permissible exposure limit (PEL) Single citation is $7,000 11
There are many changes associated with OSHA s implementation of GHS Now is the time to start taking action Develop training materials and conduct training sessions Revise workplace hazard communication plan Revise MSDS documents and product labels to comply with new Hazcom Standard 12