HAZCOM 2013 Globally Harmonized System Presentation Provided by: Illinois Emergency Management Agency Kevin Sledge Hazardous Materials Section
What is the Globally Harmonized System (GHS)? International approach to hazard communication. Provides agreed criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets. GHS was negotiated in a multi-year process by hazard communication experts from many different countries, international organizations, and stakeholder groups.
Why did OSHA decide to adopt the GHS? Improve safety and health of workers through more effective communications Provides a standardized approach (including detailed criteria for determining what hazardous effects a chemical poses) Standardized label elements assigned by hazard class and category Harmonized format of the safety data sheets
What is the phase-in period? December 1, 2013 June 1, 2015 December 1, 2015 June 1, 2016 By this date, employers must train employees on how to read GHS formatted labels and SDSs. Changes to labels are probably more substantial, however, employees need to understand where to find information on the SDS, especially in section 2 where critical hazard information is located. By this date, chemical manufacturers and distributors should have completed their reclassification of chemicals and be shipping GHS formatted SDSs and labels with their shipments. By this time too, a majority of your library will have turned over. Distributors have an additional 6 months beyond the June 1, 2015 date to pass along manufacturer labels and SDSs in the older formats. However, beyond December 1, 2015, all SDSs and labels in the U.S. should adhere to HazCom 2012 provisions. By this date employers should be fully compliant with HazCom 2012. That includes making any necessary updates to their HazCom program, training employees on any newly identified chemical hazards (identification of new hazards is likely during the reclassification process chemical manufacturers undertake), and updating safety data sheets libraries and secondary labels.
Major Changes Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of 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. Safety Data Sheets: Will now have specified 16 part sections
Hazard Classification Specific criteria for each health and physical hazard, along with detailed instructions for hazard evaluation and determinations as to whether mixtures or substances are covered. Establishes both hazard classes and hazard categories for most of the effects; the classes are divided into categories that reflect the relative severity of the effect Provides additional information that can be related to the appropriate response to address the hazard
Label Changes Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure, improper storage or handling of the hazardous chemical. Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards.
GHS Labeling What are the elements of a GHS Label? Signal Words Product Identifier (ingredient disclosure) Precautionary Statements and Pictograms Hazard Statements Supplier Identification
Label Changes (cont.) Hazard Statements Supplier Identification Product Identifier
Required Pictograms Generally the GHS pictograms would be smaller than the transport pictograms
Transport Pictograms
GHS Labeling Example GHS Outer Container Label (55 gallon/200 liter drum)
Safety Data Sheets (Formerly MSDS) HCS 2012 requires 16 specific sections
Data Sheet Changes Name: Safety Data Sheets, previously knows as MSDS. Uniform Format: As of June 1, 2015, the HCS will require new SDS s to include the section numbers, the headings, and associated information as revised in 2012. (See HCS Safety Data Sheet Handout) Standardized content: the type of information found in the various sections will always contain the same information. (For example, Section 8 will always include information about exposure limits, engineering controls, and protective measures including PPE).
16 Elements of a SDS 1. Identification (What is it and how is it used; manufacturer information, emergency contact information) 2. Hazard(s) Identification (Hazard Classification) 3. Composition/Information of Ingredients (includes all mixtures and all chemicals where a trade secret is claimed) 4. First Aid Measures (initial care to be given by untrained responders) 5. Fire-Fighting Measures 6. Accidental Release Information 7. Handling and Storage 8. Exposure Controls/Personal Protection 9. Physical and Chemical Properties 10. Stability and Reactivity 11. Toxicological Information 12. Ecological Information (non-mandatory) 13. Disposal Considerations 14. Transport Information (non-mandatory) 15. Regulatory (non-mandatory) 16. Other Information (last known revision of SDS)
Two (2) Federal Changes Related to Reporting Year 2013 Tier 2 Reporting 1) Federal OSHA Hazard Communication Standard (HCS 2012) 1910.1200 includes new definitions of physical hazard and health hazard. New HCS 2012 also contains new 16-part Safety Data Sheet (SDS) format AND 2) Federal Emergency Planning and Community Right-to-Know Act (EPCRA) Amendment which includes additional facility and chemical information fields. 17
Changes to OSHA s Hazard Communication Standard New Definition of Physical Hazard: "Physical hazard" means a chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits flammable gas. See Appendix B to 1910.1200 -- Physical Hazard Criteria. 18
Changes to OSHA s Hazard Communication Standard New Definition of Health Hazard: "Health hazard" means a chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard. The criteria for determining whether a chemical is classified as a health hazard are detailed in Appendix A to 1910.1200 -- Health Hazard Criteria. 19
Changes to OSHA s Hazard Communication Standard (OSHA) Side-by-Side Comparison of OSHA's Existing Hazard Communication Standard (HCS 1994) vs. the Revised Hazard Communication Standard (HCS 2012) https://www.osha.gov/dsg/hazcom/side-by-side.html 20
Changes to EPCRA (US EPA) Federal Register Vol. 77, No. 135 (41300-41316) published July 13, 2012 Changes effective January 1, 2014 (for Reporting Year 2013) Outreach to regulated facilities after testing and updates completed, most-likely in early December Changes to Tier II Manager Program Same Program, Same Look except that several fields have been added 21
Additional Tier 2 Facility Fields (Required information underlined) Latitude & Longitude reported for non-standard addresses (IL already requires this for ALL facility locations) Facility manned or unmanned; if yes, maximum number of occupants present at the facility at any one time Parent Company Information Contact information of the facility emergency coordinator, Tier 2 contact information, and email addresses of the owner/operator and emergency contacts Updated (2012) NAICS look-up Identity if facility is subject to EPCRA 302 (EHS), Toxic Release Inventory (TRI) and/or Clean Air Act (CAA) 112(r) Risk Management Program (RMP). If yes to TRI &/or RMP, enter facility s Identification Number(s) 22
EPCRA Section 313 - TRI TRI = Toxic Release Inventory EPCRA Section 313 requires EPA and States to collect data annually on releases & transfers of certain toxic chemicals Pollution Prevention Act (1990) requires facilities to report additional data on waste management & source reduction activities to EPA
Clean Air Act Section 112(r) - RMP RMP = Risk Management Plan Clean Air Act Section 112(r) requires facilities to coordinate emergency response actions with local emergency planning and response organizations
Additional Tier 2 Chemical Fields Required information underlined Separate data fields for reporting pure chemical and mixtures in the chemical reporting section Report Mixture Name, Product Name, or Chemical Name as it appears on MSDS/SDS Must provide a description for the storage types and conditions (instead of using reporting codes alone). Also must indicate precise location of hazardous chemicals storage. A description field for precise location is also available Latitude/Longitude for each storage location Maximum Amount at each storage location 25
Additional Tier 2 Chemical Fields (Continued) Required information underlined Revised range codes for Amounts TPQ revision for 157 non-reactive EHS chemicals handled as solids in solution. See USEPA Website for more information: http://www2.epa.gov/epcra-tier-i-and-tier-ii-reporting/epcratier-iii-amendments-and-guidance#solids Check box indicating whether information being reported is identical to that submitted last year (IL already has this available) Check box indicating if voluntarily reporting hazardous chemicals below the reporting thresholds. 26
Subject to Change prior to 1-1-14
Hazardous Materials Section Kevin Sledge, Manager HMEP Planning Grant LEPC Membership Applications (217) 557-5476 or Kevin.Sledge@illinois.gov Anne Conwill Facility-Specific and General LEPC Planning Assistance (217) 785-9903 or Anne.Conwill@illinois.gov
Hazardous Materials Section Lori Canterbury Tier 2 Manager Planning Module Access Requests for LEPCs, Fire Depts. and other Emergency Personnel (217) 524-0890 or ema.tier2@illinois.gov Carlita Crockett and Lori Canterbury Tier 2 Manager Access Request for Facilities General Facility Tier 2 Reporting Assistance (217) 558-0559 General Number or ema.tier2mgr@illinois.gov
Additional GHS Information https://www.osha.gov/dsg/hazcom/ Hazard Communication Wallet Card [PDF* 5.7 MB] December 1, 2013 Training Requirements Fact Sheet [PDF*, 289 KB] OSHA Brief on Labels and Pictograms [PDF*, 427 KB] HCS/HazCom 2012 Final Rule Federal Register: The Final Rule was filed on March 20th at the Office of the Federal Register and available for viewing on their Public Electronic Inspection Desk. The Federal Register published the final rule on March 26, 2012. The effective date of the final rule is 60 days after the date of publication. Federal Register [PDF*, 52 MB]
Additional GHS Information HCS Comparison: HazCom 1994 and HazCom 2012 Side-by-side Redline Strikeout of the Regulatory Text HazCom 1994 Press Release: US Department of Labor's OSHA publishes final rule to update the Hazard Communication Standard (HCS) Guidance OSHA Briefs [PDF*, 260 KB] Fact Sheet Quick Cards Downloadable Pictograms August 2012 OSHA/SCHC Alliance Webinar Downloadable Hazard Communications 2012 Presentation[PPTX*, ] July 2013 OSHA/SCHC Alliance Webinar: "Hazard Communication: 1 Year of Implementation" Downloadable 2013 Hazard Communication Presentation[PPTX*] Question of the Month