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

Similar documents
OSHA s Hazard Communication Standard 2012 Adoption of GHS

Luisa Su, M.H.Sc. ROH. Whistler, British Columbia September 21, 2011

GHS RESPONSIBLE PRODUCT STEWARDSHIP. Houghton International Product Stewardship Preparing for GHS in Europe

Washington Hospital Services Transcript for HazCom 2013 and GHS for Part 1

Today, we re going to talk about the Occupational Safety and Health Administration s, or OSHA s, Hazard Communication Standard, or worker right to

Environmental Health & Safety

The HazCom Written Plan:

International Leadership Forum on Global Harmonized System Regulatory Implementation around the World. Sponsored by. Practice Specialty

STREAMLINED GUIDE TO GHS


"GHS SAFETY DATA SHEETS IN THE LABORATORY"

A Guide to GHS Labeling of Chemicals. ID Technology

SAFETY DATA SHEET. Not classified as hazardous according to criteria of Australian Safety and Compensation Council

SAFETY DATA SHEET Product Name: GLK-55 Heavy Duty Hand Soap with Microscrubbers

WINDEX ORIGINAL GLASS CLEANER

Hazard Communication Program. Program originated: 07/2002 Last Updated: 06/2016. Gordon Krueger Environmental Safety Specialist

SAFETY DATA SHEET. Not classified as hazardous according to criteria of Australian Safety and Compensation Council

Achieving Regulatory Chemical Compliance: Strategies & Approaches that Reduce Risk & Lower Costs

OFF! CITRONELLA BUCKET

GHS AND SUPPLY CHAIN IMPACT

GHS and DOT What You Need to Know Today. Bruce Carlile and John Baker COQA Meeting February 2015

OFF TRIPLE WICK CITRONELLA CANDLE

Safety Data Sheet (SDS) OSHA HazCom Standard 29 CFR (g) and GHS Rev 03.

Safety Data Sheet acc. to OSHA HCS

GLADE PLUG-INS SCENTED OIL - APPLE CINNAMON

Safety Data Sheet acc. to OSHA HCS

Safety Data Sheet acc. to OSHA HCS

Safety Data Sheet acc. to OSHA HCS

: PLEDGE MULTI-SURFACE FLOOR CLEANER

Safety Data Sheet (SDS) OSHA HazCom Standard 29 CFR (g) and GHS Rev 03.

KIWI COLOR SHINE PREMIERE INSTANT POLISH - BLACK

Safety Data Sheet (SDS) United States OSHA HazCom 2012 Standard 29 CFR Prepared to GHS Rev03.

Hazardous Materials and Chemicals

GLADE PLUGINS SCENTED OIL SWEET PEA & LILAC

The Chemical Inventory Lifecycle: Conception to Optimization

Globally Harmonized System of Classification and Labelling of Chemicals (GHS)

PLEDGE MULTI SURFACE EVERYDAY CLEANER WITH GLADE RAINSHOWER

Safety Data Sheet acc. to OSHA HCS

Safety Data Sheet acc. to OSHA HCS

Oklahoma State University Policy and Procedures

Safety Data Sheet (SDS) OSHA HazCom 2012 Standard 29 CFR Prepared to GHS Rev03.

Safety Data Sheet acc. to OSHA HCS

Safety Data Sheet (SDS) OSHA HazCom Standard 29 CFR (g) and GHS Rev 03.

Safety Data Sheet according to 1907/2006/EC (REACH), 1272/2008/EC (CLP), and OSHA GHS

Safety Data Sheet acc. to OSHA HCS

GLADE PLUGINS SCENTED OIL - APPLE CINNAMON

SAFETY DATA SHEET. Robelle Industries 3-Month Algaecide. Page 1 of 5 1. PRODUCT AND COMPANY IDENTIFICATION

GLOBALLY HARMONIZED SYSTEM OF CLASSIFICATION AND LABELLING OF CHEMICALS (GHS)

Safety Data Sheet HYDROCHLORIC ACID 0.01N 0.1N 0.05N 0.2N

TOILET DUCK THICK LIQUID TOILET BOWL CLEANER

Course Learning Outcomes for Unit VII. Reading Assignment. Unit Lesson. UNIT VII STUDY GUIDE Subpart Z: Toxic and Hazardous Substances

SAFETY DATA SHEET SSS GLASS CLEANER (#05002) Version 1.0 Revision Date 05/20/2015 Print Date 05/30/2015

KIWI LEATHER DYE BLACK

SAFETY DATA SHEET ENDURE 320 ADVANCED CARE

PLEDGE FURNITURE SPRAY (LEMON CLEAN)

Safety Data Sheet acc. to OSHA HCS

Safety Data Sheet. Product identifier. Details of the supplier of the safety data sheet

Safety Data Sheet POTASSIUM IODIDE IODATE, SOLUTION

SIGMA-ALDRICH. Material Safety Data Sheet Version 4.0 Revision Date 07/24/2010 Print Date 07/11/2011

SAFETY DATA SHEET. Polywater Europe BV Zuidhaven 9-11 Unit B CR Zevenbergen Netherlands Tel: +31 (0) polywater.

GLADE PLUGINS SCENTED OIL (CLEAN LINEN )

CHEMICAL COMPLIANCE THEWERCS.COM 1

Safety Data Sheet 1907/2006/EC, 1272/2008/EC. 1 Identification of the substance / mixture and of the company / undertaking

Accel (Concentrate) % 4.25

Safety Data Sheet acc. to OSHA HCS

GLOBALLY HARMONIZED SYSTEM OF CLASSIFICATION AND LABELLING OF CHEMICALS (GHS)

Safety Data Sheet SODIUM THIOSULFATE

Version 1.0 Revision Date 04/24/2015 Print Date 06/17/2015. Material name : Brighton Lemon Fresh Furniture Polish

SAFETY DATA SHEET OASIS PRO CLEAN ESCAPE

SAFETY DATA SHEET GENUINE JOE GLASS CLEANER GJ02103

SCRUBBING BUBBLES BATHROOM CLEANER DISINFECTANT (DIN )

MATERIAL SAFETY DATA SHEET

Safety Data Sheet acc. to OSHA HCS

SAFETY DATA SHEET KEYSTONE HIGH TEMP GRILL CLEANER

GLADE CANDLE - STRAWBERRIES & CREAM

GLADE PLUG-INS SCENTED GEL - TROPICAL MIST

IncuCyte Cytotox Green Reagent

GLADE ROOM SPRAY - CASHMERE WOODS

DRANO DUAL FORCE FOAMER CLOG REMOVER

THE UNIVERSITY OF OKLAHOMA HAZARD COMMUNICATION POLICY

SAFETY DATA SHEET. Restrictions on use : Reserved for industrial and professional use.

SAFETY DATA SHEET INSTRUMENT PRESOAK

Page 1 SDS Number: May 29, 2015 SAFETY DATA SHEET

Safety Data Sheet Silica Gel white

SAFETY DATA SHEET. Hair & Body Shampoo. DISTRIBUTOR 24 HR. EMERGENCY TELEPHONE NUMBERS IDC Corporation

WINDEX POWERIZED FOAMING GLASS CLEANER

Solid Ink - Black, Cyan, Magenta, Yellow

Safety data sheet according to 1907/2006/EC, Article 31

SAFETY DATA SHEET according to Regulation (EC) No. 453/2010 Dental Use

Hazard Communication Program. University of San Diego

Safety Data Sheet acc. to OSHA HCS

EDGE INFUSED - LOTIONIZED SHAVE GEL - HYDRATE

Safety Data Sheet. Product identifier. Details of the supplier of the safety data sheet

NimkarTek Technical Services Pvt. Ltd.

Material Safety Data Sheet

GLADE CARPET & ROOM ODOR ELIMINATOR - FRESH SCENT FOR PET ODORS

DRANO ADVANCED SEPTIC TREATMENT

PLEDGE NATURAL BEAUTY- LEMON AEROSOL

SAFETY DATA SHEET. Product Name: Wire Pulling Foam Lubricant. 1. Identification of the substance/mixture and of the company. 1.1 Product identifier

Transcription:

Globally Harmonized System (GHS): Compliance Strategies Jim Larson, CPEA, CHMM EORM Principal Consultant larsonj@eorm.com 408.790.9241

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 14001 and OHSAS 18001 Certified 2

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 www.eorm.com 3

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 50001 Business Continuity Planning Sustainability Services 4

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

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

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 2012. Right to Understand http://www.osha.gov/dsg/hazcom/hazcom-faq.html 7

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

Current Labeling System (Caffeine Example) From Merck w/ modification http://www.emdmillipore.com LD50 oral: 261 mg/kg New Zealand:

Labeling Under GHS (Caffeine Example) From Merck w/ modification http://www.emdmillipore.com Danger Acute toxicity, oral

Where Should I Begin? 11

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

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

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) www.unece.org/trans/danger/publi/ghs/implementation_e.html#c25877 Federal / State Regulatory Updates Regulatory Conferences Association Meetings 14

Federal OSHA Timeline Key implementation dates: http://www.osha.gov/dsg/hazcom/effectivedates.html 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. 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

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 http://www.airliquide.com/ 17

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

Hazard Types & Classes 19

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

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 Hazard pictograms SDS 16-section format Note: Dual program requirements (until regulation is fully phased) OSHA s Model Training Program: http://www.osha.gov/dsg/hazcom/mtp101703.html 22

Finally: Update Your Program Integrate new GHS requirements into the written program HazCom Program elements: http://www.osha.gov/dsg/hazcom/solutions.html Communicate any new hazards identified Due June 1, 2016 23

How Often Should I be Assessing our Progress? 24

Summary of Federal Timeline Key implementation dates: http://www.osha.gov/dsg/hazcom/effectivedates.html 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

Useful Links OSHA GHS Fact Sheets www.osha.gov/dsg/hazcom/hcsfactsheet.html OSHA GHS QuickCards www.osha.gov/dsg/hazcom/ghsquickcards.html Official UN GHS Website (Country by Country comparison) www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html Comparing GHS to Federal HazCom by Line Item www.osha.gov/dsg/hazcom/ghoshacomparison.html#footnote1 Classification, Labeling & Packaging (CLP) Regulations echa.europa.eu/legislation/classification_legislation_en.asp Shipping by Hazard Category, Signal Word, and Hazard Statements www.sitehawk.com/ghs_hazard_physical_content.html 26

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

Jim Larson, CPEA, CHMM EORM Principal Consultant larsonj@eorm.com 408.790.9241 Thank You