Hazard Communication (HAZCOM)

and the
Globally Harmonized System of
Classification and Labeling of
Chemicals (GHS)

• Understanding the changes

2014

1
February 6, 2014
 Department of Labor
Occupational Health and Safety Administration (OSHA)
Susan Harwood Training Grant

This material was produced under Susan Harwood grant

number SH-24928-SH3 Occupational Safety and Health
Administration, U.S. Department of Labor. The contents in
this presentation do not necessarily reflect the views or
policies of the U.S. Department of Labor, nor does the
mention of trade names, commercial products, or
organizations imply endorsement by the U.S. Government.

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February 6, 2014
 Work Team

The Pennsylvania State University

University Park, PA

Outreach & Professional Education

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February 6, 2014
 Learning Objectives
At the end of this training session, you will be able to:

 Define & Describe what GHS is

 List GHS Target Sectors

 Identify and Use GHS Elements for Labeling &

Communicating to your colleagues/employees

 Understand, Describe and Construct a template of

your own Safety Data Sheet (if need be)

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February 6, 2014
 What is GHS?
• The Globally Harmonized System (GHS) is an international
approach to hazard communication, providing agreed
criteria for classification of chemical hazards, and a
standardized approach to label elements and safety data
sheets.
• The GHS was negotiated in a multi-year process by hazard
communication experts from many different countries,
international organizations, and stakeholder groups.
• It is based on major existing systems around the world,
including OSHA's Hazard Communication Standard and the
chemical classification and labeling systems of other US
agencies

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February 6, 2014
 What is GHS?
• GHS establishes
– Harmonized definitions of hazards
– Physical , health, environmental

– Specific criteria for labels

– Pictograms, signal words, hazard and
precautionary statements

– Harmonized format for safety data sheets

– 16 sections (ANSI format)
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February 6, 2014
 How was GHS developed?

• United Nations Organization (UN) initiative

since 1992 to provide a system for the
standard handling of chemicals

• The system used as reference several

existing system from various countries. It
is now
available for adoption by competent authorities around
the world.
• Revision 3 of the GHS was be used by OSHA as the
reference for the proposed Hazard Communication rule (5th
edition is out)

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February 6, 2014
 Principles of Harmonization

 Harmonization should not reduce the level of

protection.
 Requires changes in all existing systems .
 The scope includes both hazard classification
criteria and hazard communication tools (labels,
SDS’s).

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February 6, 2014
 Principles of Harmonization

 Target audiences include consumers, workers,

transport workers and emergency responders.

 Information should be presented in a

comprehensive manner to all audiences

 Regarding chemicals Confidential Business

Information (CBI) should be protected without
compromising worker safety.

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February 6, 2014
 Guiding Principles

• All hazardous chemicals are covered to some

extent, including mixtures

• The GHS does not include requirements for

additional testing for health hazards nor establishes
uniform test methods

• The system should take account existing data from

testing for hazard determination.

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February 6, 2014
 Why is the GHS needed?

• The correct handling of chemicals requires that

material information be provided by means of
labels, symbols and data sheets.

• Differences in countries regulations have resulted in

non standardized information for the same material
leading to mishandling and /or unsafe situations

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February 6, 2014
 Why is the GHS needed?
• These differences impact both
protection and trade.
• Protection: inconsistent information
for the same chemical can lead to
mishandling.
• Trade: compliance with multiple
regulations regarding hazard
classification and labelling is costly
and time-consuming.

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February 6, 2014
 Application of GHS
• The system is created as a “building-block”
(modular) approach
– This means that each authority/agency/
adopts the “blocks” that are applicable to
existing or new regulations under their scope

• For Example: one regulatory agency is

expected to adopt provisions for various
elements such as labels and SDS, while the
other agency only adopts provisions for labels
due their sector of interest

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February 6, 2014
 Building Block approach
Hazard classes

Health Physical

Acute
Skin Explosives
Toxicity

Category 1-4 Category 1-6

The building blocks are the hazard classes and categories and each competent
authority adopts the building blocks that are applicable to their specific sector.

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February 6, 2014
 Target Sectors
GHS targets these sectors :

• Workplace
• Consumers
• Transport
• Emergency Responders

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February 6, 2014
 GHS impact
Based on those sectors GHS impacts several US
agencies:

• Environmental Protection Agency (EPA)

– Pesticides Program

• Consumer Product Safety Commission (CPSC)

– User end of products or materials

• Department of Transportation (DOT)

– Hazardous Materials Regulations

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February 6, 2014
 GHS impact
• Occupational Safety and Health Administration
(OSHA)
– Under HAZCOM, OSHA has more requirements affected
by the GHS than any other US agency
• hazards,
• labels,
• safety data sheets,
• training

– Main impact is on the Hazard Communication Standard

which covers 945,000 hazardous chemical products and
7 million workplaces.
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February 6, 2014
 HCS History
• First publication on Nov.1983. Only covered
manufacturing sector. Final Rule was published on
Aug 1987 covering all employers except for the
construction industry (temporary)

• Supreme Court decision to enforce all provisions in

all industrial segments was on Feb 1990.

• Publication of final rule on Feb. 1994 including

technical amendments and minor changes

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February 6, 2014
 HCS Framework

• Purpose - to ensure that the hazards of all

chemicals produced or imported are evaluated, and
that information concerning their hazards is
transmitted to employers and employees.

• Scope – worksites where employees could be

exposed to hazardous chemicals

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February 6, 2014
 HCS Framework

• How – transmitting information by means of a

complete hazard communication program that
includes:
• list of hazardous chemicals present
• container labeling and other forms of warning,
• safety data sheets and
• employee training

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February 6, 2014
 Responsibilities under HCS
• OSHA requires manufacturers and importers to
evaluate the hazards related to chemicals they
produce or import.
– This evaluation will be changed to a hazard classification

• Employers are required to inform their employees

about the hazards related to chemicals they might
be exposed to and corresponding protective
measures.
– Labels and safety data sheets change
– Training needs to include GHS adopted elements

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February 6, 2014
 GHS main elements
• Classification criteria
– Standardized for health, physical and
environmental hazards

• Hazard communication elements

– Labels
• Standardized elements and format
– Safety Data Sheets
• Standardized sections and format

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February 6, 2014
• Health, Physical, Environmental

GHS – Hazard Classification

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February 6, 2014
 GHS: Environmental Hazards
• Hazardous to the Aquatic Environment
Acute – injury after short term exposure
Chronic – injury during the organism life cycle
- Includes fish, crustaceans, and algae or other
aquatic plants

• The environmental hazards are not covered by

OSHA . The competent authority for those would
be EPA
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February 6, 2014
 GHS Health Hazards (10)
• Acute Toxicity
• Skin corrosion/Irritation
• Serious eye damage/eye irritation
• Respiratory or skin sensitization
• Germ cell mutagenicity
• Carcinogenicity
• Reproductive toxicity
• Specific Target organ toxicity – Single exposure
• Specific Target organ toxicity – repeated exposure
• Aspiration hazard

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February 6, 2014
 Definitions: Health Hazards
• Acute toxicity “refers to those adverse
effects occurring following oral or dermal
administration of a single dose of a
substance, or multiple doses given within
24 hours, or an inhalation exposure of 4
hours”.

– Substances are assigned to one of five

included categories based on oral,
dermal, and inhalation toxicity.
OSHA did not adopt category 5

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February 6, 2014
 Definitions: Health Hazards
• Skin corrosion is defined as “the
production of irreversible damage to
the skin; namely, visible necrosis
through the epidermis and into the
dermis, which was followed by the
application of a test substance for up Visible damage to
skin after contact
to 4 hours”. with substance
– GHS does not require additional testing.
Based on available data for that
chemical
• Corrosive reactions are typified by ulcers,
bleeding, bloody scabs.
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February 6, 2014
 Definitions: Health Hazards

• Skin irritation is defined as “the

production of reversible damage to
the skin following the application of a
test substance for up to 4 hours”.
Before contact

OSHA adopted two categories

After contact
for the Skin Corrosion/irritation
hazard class

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February 6, 2014
 Definitions: Health Hazards

• Skin sensitizer “means a

chemical that induces an
allergic response following
skin contact”.

• Respiratory sensitizer “means a chemical that will

lead to hypersensitivity of the airways following
inhalation of the chemical”.
– There are two categories for the Respiratory or Skin
Sensitization hazard class

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February 6, 2014
 Definitions: Health Hazards
• Two categories for eye hazards

• Eye irritation is defined as “the production of

changes in the eye following the application of test
substance to the anterior surface of the eye, which
are full reversible within 21 days of application”.

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February 6, 2014
 Definitions: Health Hazards

• Serious eye damage is defined as the production of

tissue damage in the eye, or serious physical decay
of vision, following application of a test substance to
the anterior surface of the eye, which is not fully
reversible within 21 days of application”.

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February 6, 2014
 Definitions: Health Hazards
• Germ Cell Mutagenicity
• A mutation “is defined as a
permanent change in the amount
or structure of the genetic material
in a cell”.
• The term mutagenic and mutagen “will
be used for agents giving rise to an
increased occurrence of mutations in
populations of cells and/or organisms”.
• Two categories in this hazard class

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February 6, 2014
 Definitions: Health Hazards
• Carcinogen “means a substance or
a mixture of substances which
induce cancer or increase its
incidence.”
Skin cancer
– Substances and mixtures which have
induced benign and malignant tumors
in well-performed experimental studies
on animals are considered also to be
presumed or suspected human
carcinogens.

• Two categories in this hazard Lung cancer

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February 6, 2014
 Definitions: Health Hazards
• Reproductive toxicity “includes
adverse effects on sexual function
and fertility in adult males and
females, as well as adverse effects
on development of the offspring”.
– Adverse effects on development of the
offspring means “any effect of
chemicals which interferes with normal
development of the conceptus either
before or after birth”.

• Two categories in this hazard

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February 6, 2014
 Definitions: Health Hazards

• Specific Target Organ Toxicity

(STOT)
– Single exposure means
“specific, non-lethal target
organ toxicity arising from a
single exposure to a chemical”.
– Repeated exposure requires
more than one instance of
exposure.

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February 6, 2014
 Definitions: Health Hazards
• STOT is caused by chemicals that are
specific target organ toxicants and, as
such, present a potential for adverse
health effects in people who are
exposed to it.
– STOT – single exposure has three hazard
categories
– STOT – repeated exposure has two
hazard categories.

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February 6, 2014
 Definitions: Health Hazards
• Aspiration means “the entry of a liquid or solid
chemical directly through the oral or nasal cavity, or
indirectly from vomiting, into the trachea and lower
respiratory system”.
– Includes severe acute effects such as chemical
pneumonia, varying degrees of pulmonary injury or death
following aspiration.
– Two categories but Only one
category adopted by OSHA

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February 6, 2014
New Definitions…

GHS – Physical Hazards

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February 6, 2014
 GHS Physical Hazards (16)
• Explosives
• Flammable gases
• Flammable aerosols
• Oxidizing gases
• Gases under pressure
• Flammable liquids
• Flammable solids
• Self-reactive substances and mixtures
• Pyrophoric liquids
• Pyrophoric solids
• Self-heating substances and mixtures
• Substances and mixtures which, in contact with water, emit
flammable gases
• Oxidizing liquids
• Oxidizing solids
• Organic peroxides
• Corrosive to metals

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February 6, 2014
 Physical Hazards…

• Explosive Substances and

Mixtures
• Solid or liquid substances
capable of producing gas at
such a high temperature and
pressure that it can cause
damage to surroundings.
• Divided into 7 categories
based on type of damage
produced

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February 6, 2014
 Physical Hazards...
• Flammables, include
– Flammable Gases
– Flammable Aerosols
– Flammable Liquids
– Flammable Solids

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February 6, 2014
 Physical Hazards...
• Flammable gas means a gas
having a flammable range with air
at 20°C (68°F) and a standard
pressure of 101.3 kPa (14.7 psi).
– Two categories

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February 6, 2014
 Physical Hazards...

• Flammable Liquids
– Any liquid with a flash point of
93°C (199.4°F) or less.
– Four categories

• Flammable Solids means a solid,

usually in a powder or granular
form, that is easily combustible
through friction
– Two categories

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February 6, 2014
 Physical Hazards...
• Aerosol means “any non-refillable receptacle
containing a gas compressed, liquefied or
dissolved under pressure, and fitted with a release
device allowing the contents to be ejected as
particles in suspension in a gas, or as a foam,
paste, powder, liquid or gas.”

• Flammable Aerosols
– Contain Flammable components
– Two categories

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February 6, 2014
 Physical Hazards …
• Oxidizing gas “means any gas which
may, generally by providing oxygen,
cause or contribute to the combustion
of other material more than air does”.
One category.
• Oxidizing Liquids and Solids
– Though not necessarily combustible on
their own, generally by yielding oxygen
cause or contribute combustion of other
material.
– Three categories

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February 6, 2014
 Physical Hazards ...
• Gases Under Pressure
– Gases contained in a receptacle
at a pressure of 200 kPa (29 psi)
or more, which are liquefied or
liquefied and refrigerated

– Includes 4 groups: compressed

gases, liquefied gases, dissolved
gases and refrigerated liquefied
gases

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February 6, 2014
 Physical Hazards …
• Self-reactive substances & mixtures are
thermally unstable liquid or solid
chemicals liable to undergo a strongly
exothermic decomposition even without
participation of oxygen (air).
• Divided in 6 categories similar to those in
the transport sector

• Excludes oxidizers, organic peroxides and

explosives.

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February 6, 2014
 Physical Hazards …
• Pyrophoric Solids / Liquids means a
solid or liquid “which, even in small
quantities, is liable to ignite within
five minutes after coming into
contact with air”.

– Mildly pyrophoric solids can be handled in

the air for brief periods of time.

– One category for each

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February 6, 2014
 Physical Hazards …
Self-Heating Substances & Mixtures
– Solids or liquids, other than pyrophoric, which by reaction
with air and without energy supply is liable to self heat.
(Two categories)

– They require large amounts of material and long periods

of time to ignite.

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February 6, 2014
 Physical Hazards …
• Substances & Mixtures which in contact with
water, Emit Flammable Gas are solid or liquid
chemicals which, by interaction with water, are
liable to become spontaneously flammable or to
give off flammable gases in dangerous quantities

– Divided into 3 categories

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February 6, 2014
 Physical Hazards …
• Corrosive to Metals “means a
chemical which by chemical action
will materially damage, or even
destroy, metals”
– One category.

• Organic Peroxides
– Organic liquids or solids that can
decompose explosively, burn rapidly,
be sensitive to friction and react
dangerously with other chemicals.
– 7 categories adopted similar to those in
transport sector

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February 6, 2014
Labels

GHS – Hazard Communication Tools

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February 6, 2014
 Product Identifier
 States the identity of the chemical, including all the
ingredients that contribute to the hazard of the
mixture.

 Unique means by which the chemical can be

identified within the particular use setting.

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February 6, 2014
These are new…

GHS - Pictograms

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February 6, 2014
 Pictogram Shape & Colour

 For transport, pictograms will not change

 For other sectors, pictograms will have a black

symbol on a white background with a red diamond
frame.

 For the same hazard, where a transport pictogram

appears, the GHS pictogram should not appear.

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February 6, 2014
… On the labels

GHS - Hazard statements

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February 6, 2014
 Hazard Statements
• GHS label should include appropriate hazard and
precautionary information.

• A hazard statement is a phrase assigned to a

hazard class that describes the nature of the
hazard, and its level of severity.
• “Highly Flammable,” “Unstable Explosive,” “Toxic
if Inhaled”.

• There are three types: Physical, Health and

Environmental

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February 6, 2014
 Precautionary Information
 Phrases indicate measures recommended to help
minimize or prevent the effects resulting from
exposure, improper storage or handling of
hazardous products

 Precautionary statements include provisions for

storage, handling, response and disposal

 Appendix C contains, among other information,

statements recommended for each level of hazard
within each hazard class.

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February 6, 2014
Appendix C

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February 6, 2014
 Precedence

• Where a chemical is classified for a number of

hazards, and the precautionary statements are
similar, the most stringent shall be included on the
label (this will be applicable mainly as preventive
measures).

• An order of precedence may be imposed by the

manufacturer, importer or responsible party in
situations where phrases concern “Response.”

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February 6, 2014
From MSDS to SDS

GHS – Hazard Communication Tools: Safety

Data Sheets

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February 6, 2014
 Role of the SDS in the GHS
Primary Use of SDS: The Workplace
 Employers and workers use them as an
information source about hazards of a
chemical substance or mixture and to
obtain advice on safety precautions.

 SDS information can be used by those

involved in the transport of dangerous
goods and emergency responders.

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February 6, 2014
 When is an SDS required?
 An SDS should be produced for all chemicals
(substances and mixtures) which meet the
harmonized criteria for physical, health or
environmental hazards under the GHS and …

 For all mixtures which contain substances that

meet the criteria for:
 Carcinogens,
 Toxic to reproduction or
 STOT in concentrations exceeding the cut-off limits
specified by the criteria for mixtures.

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February 6, 2014
 Safety Data Sheet content
1. Identification
2. Hazard (s) identification
3. Composition/ information on ingredients
4. First-aid measures Sections 1-11 and 16 are
5. Fire-fighting measures mandatory for informational
6. Accidental release measures requirements
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 Not under OSHA jurisdiction for
14. Transport information informational requirements
15. Regulatory information
16. Other information

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February 6, 2014
Global Harmonization System (GHS)

Exercises

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February 6, 2014
 Exercise on Pictograms
Determine what pictogram would use the following
chemical using the information provided

A. Material is extremely toxic to humans

B. Keep away from flames and sparks.

C. Corrosive to metals

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February 6, 2014
 Exercise on Hazards
Determine the type of precautionary statement
(prevention, response, storage, disposal) of these
materials given the following information

A. Wear cold insulating gloves

B. Dispose of contents in accordance with local

regulations

C. If exposed: call poison center or doctor/ physician

D. Stored in a well ventilated place

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February 6, 2014
 Data Sheets Exercise

Using the handout provided, identify in which section

of the data sheet you can find the following:

A. Health effects
B. Flammability of material
C. Storage precautions
D. Toxicity of material
E. Material identity

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February 6, 2014
 Labels Exercise

With the information provided for each chemical,

identify the following elements of the label. Please
reference Appendix C.

A. Pictogram
B. Signal words
C. Hazard statements
D. Precautionary statement

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February 6, 2014
The Changes to HCS

Old vs. new….

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February 6, 2014
 Past rule
• Current HAZCOM standard rule
– (a) Purpose
– (b) Scope and Application
– (c) Definitions
– (d) Hazard Determination
– (e) Written Hazard Communication Program
– (f) Labels and Other Forms of Warning
– (g) Material Safety Data Sheets
– (h) Employee Information and Training
– (i) Trade Secrets
– (j) Effective Dates
– Appendix A - E
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February 6, 2014
 Past rule to be revised
• Appendices
• Appendix A (mandatory) – Health hazards definitions

• Appendix B (mandatory) – Hazard determination

• Appendix C (advisory) – Information sources [removed

1996]

• Appendix D (mandatory) – Trade secret definition

• Appendix E (advisory) – Compliance guidelines

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February 6, 2014
 Organization of HazCom 2012
• (a) Purpose
• (b) Scope and Application
• (c) Definitions
• (d) Hazard Classification
• (e) Written Hazard Communication Program
• (f) Labels and Other Forms of Warning
• (g) Safety Data Sheets
• (h) Employee Information and Training
• (i) Trade Secrets
• (j) Effective Dates
• Appendices A -F

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February 6, 2014
 … HazCom 2012
• Appendices
• Appendix A (mandatory) – Health hazards criteria

• Appendix B (mandatory) – Physical criteria

• Appendix C (mandatory) – Allocation of Label Elements

• Appendix D (mandatory) – Safety Data Sheets

• Appendix E (mandatory) – Definition of “Trade Secret”

• Appendix F (non mandatory) - Guidance for Hazard Classifications Re:

Carcinogenicity

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February 6, 2014
 HazCom 2012 changes
• Basic Framework will not change
– The scope and application is basically
unchanged

– Minimum changes to written program

requirements, worker training, and trade secret
provisions

• Changes from performance oriented to

specification standard using standard criteria

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February 6, 2014
Section comparison

Where are the changes?

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February 6, 2014
 Purpose

• (a) Purpose
– The primary modification to this paragraph is to
state affirmatively that part of the purpose is to
harmonize with international requirements..

– The word evaluation was substituted with

classification to be consistent with GHS
provisions

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February 6, 2014
 Scope and Application
• (b) Scope and Application

– No substantive changes are proposed, only

terminology changes in accordance with GHS
• Hazard determination changed to hazard
classification
• Use of word classify, in lieu of assess
• MSDS are changed to Safety Data Sheets

– Elimination of Appendix E reference

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February 6, 2014
 Definitions

• (c) Definitions

– OSHA has changed a number of the definitions,

as well as the actual terms used, to be consistent
with the GHS.

– The terms removed from this section are

generally relevant primarily to the hazard
classification process which are defined in
Appendices A (Health hazards) and B
(Physical hazards).

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February 6, 2014
 Definitions: Health Hazards

 Health hazards are assigned to Appendix A of the

HazCom 2012 regulation

 Appendix A includes information related to the

principles of classification from GHS Parts 1 & 3

 Definitions and specific classification criteria from

GHS Part 3 is discussed

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February 6, 2014
 Definitions: Physical Hazards
 Physical hazards are assigned to Appendix B of
HazCom 2012

 Appendix B begins with information related to the

principles of classification from GHS Parts 1 & 2

 Definitions and specific classification criteria were

adopted to be consistent with GHS

94
February 6, 2014
How to determine hazard…

GHS- Hazard classification

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February 6, 2014
 HazCom 2012 changes
(d)Hazard Classification
– Appendixes A and B covers criteria for health and
physical hazards, respectively

– OSHA has included the general provisions for hazard

classification in paragraph (d) of the HazCom 2012, and
added extensive appendixes that address the criteria for
each health or physical effect.

– The hazard classification criteria contained in HazCom

2012 is test method “neutral.” That is, the person
classifying a chemical should use available data and no
additional testing is required to classify a chemical.

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February 6, 2014
 Hazard statements
• Hazard information contained in Appendix C
of HazCom 2012, for each hazard class:
• the pictogram,
• signal word,
• the proposed hazard statement
– Health or Physical

• the proposed types of precautionary

statements
– Prevention, Response, Storage, Disposal

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February 6, 2014
 Hazard statements

• The text of all applicable hazard statements shall

appear on the label, except as otherwise specified.

• Hazard statements may be combined where

appropriate to reduce the information on the label
and improve readability, as long as all of the
hazards are conveyed as required.

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February 6, 2014
 Hazard Statements

Where the manufacturer, importer, or distributor

chooses to add supplementary information on the
label, the placement of such information shall not
interfere with information required by this section.

99
February 6, 2014
Written program elements…

Labels, safety data sheets and training

100
February 6, 2014
 HazCom 2012 changes
(e) Written Hazard Communication Program
– The GHS does not have provisions regarding
hazard communication written programs, and
thus this paragraph is essentially the same as in
the current HCS. No substantive (only
terminology) changes have been made in this
paragraph of the HCS.
– Key elements of this program are labels,
safety data sheets and employee training

101
February 6, 2014
 HazCom 2012 changes
(f) Labels and Other forms of Warning

– Under this paragraph, chemical manufacturers

and importers must provide a label that includes
a harmonized signal word,
pictogram, and hazard and
precautionary statements for each
hazard class and category. In
addition, precautionary statements
must also be provided, as well as product
identifier and supplier information.
102
February 6, 2014
 HazCom 2012 changes
(f) Labels and Other forms of Warning

– New mandatory Appendix C indicates what

specific information is to be provided for each
hazard class and category once a
chemical is classified.

– OSHA will require the use of

pictograms, specific signal words, hazard and
precautionary statements in accordance with
GHS principles.
103
February 6, 2014
 HazCom 2012 changes
(g) SDS…
– Found in HazCom 2012 Appendix D, changes
include a 16 section format with specific
information contained in each section.
Sections 1-11, 16 are mandatory
– Section 1. Identification: The requirements in
this section are not new with two exceptions. The
format and the requirement to identify
recommendations for use of the chemical and
restrictions on use are new.

106
February 6, 2014
 HazCom 2012 changes
(g) SDS…
– Section 2. Hazard(s) identification: employer
must identify the hazards by means of a hazard
determination, and must classify a hazardous
chemical according to the changed conditions
provided in HazCom 2012 Appendices A and B.
– A separate SDS will be required for each mixture rather
than one for each chemical comprising the mixture

– Pictograms (OR NAME OF SYMBOL), standardized hazard

statements, signal words, and precautionary
statements are now required.

107
February 6, 2014
 HazCom 2012 changes
(g) SDS…
– Section 3. Composition/ information
on ingredients. No new requirements
other than format and the requirement
that a separate SDS will be required for
each mixture rather than one for each
chemical comprising the mixture
– Section 10. Stability and reactivity.
Although the information on conditions
to avoid and hazardous decomposition
products are new to HCS, it has been
required in the ANSI Z400.1 standard.
108
February 6, 2014
 HazCom 2012 changes
(g) SDS…
Sections contain no new requirements, only format
– Section 4. First-aid measures.
– Section 5. Fire-fighting measures.
– Section 6. Accidental release measures.
– Section 7. Handling and storage.
– Section 8. Exposure controls /Accidental release
measures.
– Section 9. Physical and chemical properties.
– Section 11. Toxicological information
– Section 16. Other information

109
February 6, 2014
 HazCom 2012 changes
(g) SDS…
To be GHS-compliant in the SDS, the requirements
for these sections are provided but compliance
is outside of OSHA jurisdiction.
– Section 12. Ecological information
– Section 13. Disposal considerations
– Section 14. Transportation information
– Section 15 Regulatory information

– These are all Non-mandatory sections.

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 HazCom 2012 changes
(h)Employee Information and Training
– Indicates that the new label and data sheet
formats and presentation of information must be
discussed in training. Make sure information &
training is effective.
– All employers will be required to conduct
additional training to ensure that their employees
are familiar with the standardized labels and
safety data sheets.
– Other training provisions remain the same.
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 HazCom 2012 changes
(i)Trade Secrets
– HazCom 2012 includes few changes from the
existing standard.
– The GHS requires disclosure of the percentage
composition of mixtures on the SDS. HazCom
2012 adopts this requirement, but allows the
manufacturer to claim trade secret protection for
this rule, only if worker safety is maintained
and the provisions of trade secret are
followed.

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 HazCom 2012 changes
(j)Effective Dates
– OSHA required that all of the revised
provisions in HazCom 2012 become
effective in three years (2016).
– Training is being required by 12/1/13,
so employers and employees will recognize and
understand the new labels and safety data
sheets as they are received.

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 Approach to Other Standards
• Many other OSHA standards contain criteria related
to defining hazards, as well as other provisions that
rely on those criteria

• OSHA undertook a comprehensive review of its

rules to identify what needed to be changed

• OSHA has proposed modifications to all of those

standards that it determined needed to be
consistent with the GHS

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 Other OSHA Standards
 1926.152 Flammable and Combustible Liquids

 All substance specific standards that contain a

generic hazard communication statement.

 1910.119 Process Safety Management Standard

 1910.1450 Occupational Exposure to Hazardous

Chemicals in Laboratories

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Global Harmonization System(GHS)

Summary and
References

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February 6, 2014
 Why does OSHA needs it?

• OSHA’s Hazard Communication Standard (HCS)

has performance-oriented requirements for labels
and safety data sheets, producing inconsistencies
in the communication of the hazard

• A standardized approach for labels and safety data

sheets is preferred. Adoption of the GHS will
address this domestic concern and also align
OSHA with DOT’s Hazard Criteria

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February 6, 2014
 HazCom 2012 rule
• Under HazCom 2012, the hazard determination
requirements are not performance-oriented.
– Definitions section, Appendix A and B provide
information for health and physical hazard
determination

• HazCom 2012 uses the GHS concept of

“classification” instead of determination of a
hazardous effect .
– Appendix C provides hazard criteria for
classification

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February 6, 2014
 HazCom 2012 changes
• Hazard classification: Provides
specific classification criteria for
health and physical hazards, for
chemicals (substances / mixtures).

• 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.

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 HazCom 2012 changes
• Safety Data Sheets: Will now have
a specified 16-section format.

• Information and training: HazCom

2012 requires that workers are
trained by 12/1/13 to facilitate
recognition and understanding of the
new labels and safety data sheets.

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 How does this affect the workplace?
• Employers
– Initial employee training on pictograms, signal words,
hazard and precautionary statements by 12/1/13
– Training on new SDS format
– Continue to maintain the updated labels & SDSs.
Update within 3 months of new and significant
information for SDS’s & 6 months for labels.

• For manufacturers
– Initial start-up costs associated with reclassification,
producing new labels, safety data sheets, training

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 Benefits of Harmonization

• Benefits for users and producers of chemicals,

countries, and international organizations.
 Enhance protection of humans and
environment.
 Facilitate chemical international trade.
 Reduce duplicate testing and evaluation.
 Aid countries and international organizations in
the proper handling of chemicals.

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 Additional Information

• OSHA’s website on GHS

– http://www.osha.gov/dsg/hazcom/global.html

• UN Website
– http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html

• The Pennsylvania Technical Assistance Program

– http://www.penntap.psu.edu

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HAZCOM- GHS

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