Globally Harmonized System (GHS): Compliance Strategies. Jim Larson, CPEA, CHMM EORM Principal Consultant

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1 Globally Harmonized System (GHS): Compliance Strategies Jim Larson, CPEA, CHMM EORM Principal Consultant

2 About EORM History Founded in 1990 by Environmental, Health and Safety (EHS) managers to offer comprehensive EHS management and technical consulting services to the high tech industry In late 90s, successfully diversified our client base into multiple regional and vertical markets across the US and beyond Today 140 employees supporting 350 customers from 6 regional offices in US; HQ in San Jose, CA Multidisciplinary EHS and Sustainability consulting team Well-established strategic partnering arrangements allowing for cost effective and highly responsive international support ISO and OHSAS Certified 2

3 What EORM Does At EORM we make a positive impact on the world every day. We do this by enabling companies to be socially and globally responsible, protecting employees, preserving the environment, and building long-term sustainable solutions. Find out more on our website at 3

4 EORM Services EHS Auditing EHS Compliance Environmental Compliance Ergonomics Industrial Hygiene Process Safety Safety Engineering Asbestos, Lead, Mold & Remediation (Phase I-III) Construction EHS Services EHS Outsourcing Management Consulting EHS Strategic Planning Management Systems» ISO 14K, OHSAS 18K, ISO 28K, ISO Business Continuity Planning Sustainability Services 4

5 Introductions Jim Larson Principal Consultant Certified Professional Environmental Auditor Certified Hazardous Materials Manager Experience in industry & consulting 5

6 Agenda What is the GHS Vision / Legislation for GHS OSHA Timeline Transitioning Your Organization What Has to be Updated? Hazard Types, Classes, Categories Audience Discussion Summary w/ Helpful Links 6

7 What is the GHS? United Nations (UN) Globally Harmonized System (GHS) of Classification and Labeling of Chemicals Worldwide initiative to promote a standardized classification and labeling of chemicals. Adopted in 1992 Activities, preparation, and implementation varies by country GHS is not a regulation or standard OSHA adopted GHS elements into the HazCom Standard in May Right to Understand 7

protection of workers / public from chemical hazards Recognized framework

8 GHS Benefits Increase quality / consistency for communicating hazards Data driven to enhance protection of human health & environment Improve protection of workers / public from chemical hazards Recognized framework for countries without existing systems Facilitate international trade Reduce fatalities 8

9 Current Labeling System (Caffeine Example) From Merck w/ modification LD50 oral: 261 mg/kg New Zealand:

10 Labeling Under GHS (Caffeine Example) From Merck w/ modification Danger Acute toxicity, oral

11 Where Should I Begin? 11

12 Where Should I Begin? Stay informed Complete a gap analysis Evaluate your chemical inventory Acquire & maintain SDS Re-label chemical containers Evaluate alternative workplace labeling Train affected employees Update the written program Communicate any new hazards 12

13 Questions to Consider Are you familiar with the standard(s)? Where are your facilities located? When was your written plan reviewed? What are your methods of delivering training? What role will your internal/external vendors play? What recent business changes have/will occur? What resources do you have? 13

14 Stay Informed Learn how GHS elements will affect your organization Understand when countries implement GHS elements (varies by country) United Nations Economic Commissions for Europe (UNECE) Federal / State Regulatory Updates Regulatory Conferences Association Meetings 14

Federal OSHA Timeline Key implementation dates: http://www.

html Dec 1, 2013 June 1, 2015 Dec 1, 2015 June 1, 2016

safety data sheet (SDS) format Chemical manufacturers,

provisions of the final rule Except: Distributors shall not

importer unless it has a GHS label Employers to update

15 Federal OSHA Timeline Key implementation dates: Dec 1, 2013 June 1, 2015 Dec 1, 2015 June 1, 2016 Employers must train employees on new label elements & safety data sheet (SDS) format Chemical manufacturers, importers, and employers must comply with all modified provisions of the final rule Except: Distributors shall not ship containers labeled by the chemical manufacturer or importer unless it has a GHS label Employers to update alternative workplace labeling and hazard communication programs Provide additional employee training for new hazards 15

Complete A Gap Analysis Transitioning your organization will take time Having a prioritized strategy is helpful EORM recommendation: Full Phased Approach vs.

16 Complete A Gap Analysis Transitioning your organization will take time Having a prioritized strategy is helpful EORM recommendation: Full Phased Approach vs. waiting for key deadlines If actively implementing, how often should you re-assess? Evaluate current methods/activities and how your organization defines select terminology 16

17 Chemical Inventory & SDSs How accurate and when was your last chemical inventory? How do you acquire/manage SDS? Do you need to re-author SDS? 30-year MSDS (SDS) requirement Various regulations require employers to maintain MSDS /SDS after an exposure or incident involving exposure 17

18 Classification of Hazards Hazard Types Physical, Health, & Environmental Hazard Classes Refers to the nature of the physical, health or environmental hazard, such as flammable solid, carcinogen, acute toxicity, etc. Hazard Categories Each hazard class contains five (5) hazard categories 18

19 Hazard Types & Classes 19

20 Hazard Category Designation Hazard category may or may not have a pictogram indicating nature of the hazard NFPA hazard numerical designation concern Evaluate alternative workplace labeling Less Hazardous 20

21 Label Requirements Product Identifier: chemical identity of the hazardous substance. Needs to match SDS Pictogram: while most pictograms will consist of the symbol in a red diamond, some counties allow use a black border in certain instances Signal Word (if indicated): Either Danger (more severe) or Warning (less severe) Hazard Statement(s) Precautionary Statement(s) There are four types: prevention, response, storage, and disposal Name, Address & Phone # of Manufacturer, Importer, or Responsible Party 21

Train Affected Employees Evaluate training and method of delivery Training must be completed by December 1, 2013 (Fed-OSHA) Review should include the new: Signal words and labeling

22 Train Affected Employees Evaluate training and method of delivery Training must be completed by December 1, 2013 (Fed-OSHA) Review should include the new: Signal words and labeling Hazard pictograms SDS 16-section format Note: Dual program requirements (until regulation is fully phased) OSHA s Model Training Program: 22

elements: http://www.osha.gov/dsg/hazcom/solutions.

23 Finally: Update Your Program Integrate new GHS requirements into the written program HazCom Program elements: Communicate any new hazards identified Due June 1,

24 How Often Should I be Assessing our Progress? 24

25 Summary of Federal Timeline Key implementation dates: Dec 1, 2013 June 1, 2015 Dec 1, 2015 June 1, 2016 Employers must train employees on new label elements & safety data sheet (SDS) format Chemical manufacturers, importers, and employers must comply with all modified provisions of the final rule Except: Distributors shall not ship containers labeled by the chemical manufacturer or importer unless it has a GHS label Employers to update alternative workplace labeling and hazard communication programs Provide additional employee training for new hazards 25

26 Useful Links OSHA GHS Fact Sheets OSHA GHS QuickCards Official UN GHS Website (Country by Country comparison) Comparing GHS to Federal HazCom by Line Item Classification, Labeling & Packaging (CLP) Regulations echa.europa.eu/legislation/classification_legislation_en.asp Shipping by Hazard Category, Signal Word, and Hazard Statements 26

27 Audience Discussion What BMPs Have You Learned? What advice do you have? What challenges have you encountered? How has the new requirements affected your organization? How are you managing SDS in other countries? 27

28 Jim Larson, CPEA, CHMM EORM Principal Consultant Thank You

OSHA s Hazard Communication Standard 2012 Adoption of GHS

OSHA s Hazard Communication Standard 2012 Adoption of GHS Kami Blake Solutions Engineer 3E Company May 2, 2012 1 Agenda Time Line of New OSHA Hazard Communication Standard (HCS) Brief GHS Review Major