Case Study for Globally Harmonized System

(GHS) Implementation in Industry

Prepared for NC ASSE by Stephen Wrightenberry – Intern Cree EHSPresented by Erin Hite – EHS Program Manager, Cisco Systems

ASSE Chapter meeting 12/13/12

Overview of a sample plan to implement GHS in an industrial setting.◦ Objectives◦ Challenges◦ Plans and ideas

Will include tips and things to think about as you implement the program at your worksite.

Will not be a detailed review of the changes to the regulation (hopefully you already know the details!).

Agenda

See handout for side by side comparison of 1994 and 2012 Haz comm regulation changes

Sections with changes:◦ Purpose◦ Scope/Application◦ Definitions◦ Hazard Classification◦ Written Program◦ Labels◦ Safety Data Sheets◦ Employee Training◦ Trade Secrets

GHS Modifications to the Hazard Communication System

These directly affect employees

Compliance Plan TimelineCompliance Plan Step Planned Completion

Date(Compliance required)

Update and Publish the internal Hazard Communication Program.

June 1, 2013(June 1, 2016)

Train employees regarding the new label elements, safety data sheets (SDS) format and provide any additional employee training for newly identified physical or health hazards.

June 2013 (December 1, 2013)

Update existing labels at the site Start July 2013 (June 1, 2016)

Update existing MSDSs with newly formatted SDSs provided by the chemical manufacturer/importer.

Ongoing (June 1, 2016)

Timing for implementation – SDSs are already becoming available everywhere, need to train employees on how to read.

Training needs to cover: ◦ Changes to HazCom, 16-section SDS, new label requirements, new classification

system, any newly identified physical or health hazards on new SDSs to include in employee training

Include new label information in training ◦ Since there will be new Manufacturer labels – if internal labels remain the same it

will be confusing for employees.◦ New SDS will have classification numbers that are opposite of NFPA labels that

are currently in use (1 is highest hazard rather than lowest hazard)

Classification system is more complicated. Individual employees may not be able to make label choices without EHS assistance.

Pictograms – new for employees – different from numbered hazard rating

Challenges for Implementation- Training

Training Materials• Online Powerpoint class – required

for all employees.• Updated website – with links to

information and contacts for help• Posters – for work areas, gowning

rooms, break rooms, bulletin boards• Badge Cards – for employees to carry• Newsletter – company wide prior to

training.

Sample PosterSample Badge Card Materials from: GHS Compliance Kit KHA Online-MSDS

1) Identification of the substance or mixture and of the supplier2) Hazards identification3) Information on ingredients (composition) substance/mixture4) First Aid Measures5) Firefighting Measures6) Accidental Release Measures7) Handling and Storage8) Exposure controls/Personal protection9) Physical and Chemical Properties10) Stability and Reactivity11) Toxicological12) Ecological Information (Non-mandatory)13) Disposal Considerations (Non-mandatory)14) Transport Information (Non-mandatory)15) Regulatory Information (Non-mandatory)16) Other information including information on preparation and revision of the SDS

Train on 16-Section Safety Data SheetFocus in

employee Training will be on changes to these sections

New Acetone SDS – Training Focus

Pictograms and what

they mean

Hazard Statements

Classification and how to

Interpret

Handling and

Prevention Response

Chemical Identification

Note: EHS should be aware of differences between GHS and other regulations - Example: Flammable and Combustible ranges:

LOTs and LOTs of labels! ◦ Includes: squeeze bottles, equipment, tanks, hoods, buckets,

beakers, jars and on and on!

Larger labels required – with inclusion of pictograms, hazard statements and other requirements. What to do with small containers?

Difficult to use preprinted labels for the multitude of chemicals (need all sizes, pictograms can’t be blank, who manages)

Manufacturer label pictograms need to be in color – determine if internal labels will follow this rule – requires specialized printers.

Finding printers made in the US to print updated labels (Printers available in the UK as of now; US is slowly transitioning printer labels over).

Challenges for Implementation- Labels

New HazCom regulation allows employers to use existing workplace-specific labeling systems as long as they provide the required information.

However, existing systems may not match what will now be on manufacturer labels and on the SDS.◦ Leads to confusion for employees so implementing

consistent format is a good idea.

HazCom – Workplace Labeling

Company is using NFPA/HMIS Labels on all non-manufacturer containers and equipment.

NFPA labels use number system to Rate the hazards. ◦ 4 is high hazard, 1 is low hazard

GHS labels will have pictograms and hazard statement, SDS will classify using numbers ◦ 1 is high hazard

Example

NFPA HMIS

Sample GHS

Internal labels should have the following:◦ Product Identifier◦ Pictogram◦ Signal Word◦ Hazard Statement(s)

Other:◦ Precautionary Statement(s)◦ Manufacturer contact info

Modifications to Labeling System

HazCom Pictograms and Hazards

HazCom – Example of Manufacturer’s Label

BIG!!

Will need glasses to read if use all this information if used on secondary containers!

GHS labels – no standard format.

• As you can see, the format may differ as long as the required information is present.

• May need to have several options available for internal labels to accommodate container size and type of hazard.

Example preprinted label• Manu. labels require

red outlines for pictograms.

• Blank diamonds are not permitted on a label from manufacturer, but currently ok for site labels

• Might change!• Black out

pictograms that are not applicable?

• Need to train employees how to complete label

• What to do if updated SDS is not available?

Using in house printing will cut time in receiving labels and will also expedite the process, since labels can be designed, printed, and then posted.

Important to find a cost effective printer that can handle all necessary applications.

Would be great if integrated with existing MSDS system so labels would auto print based on specific MSDS information.

Printing Options

◦ MSDS online system Costs for uploading new SDSs, Implementing label printing module (configure information

from MSDS to label, train employees on how to use)◦ Manpower for requesting updated SDSs from all

manufacturers◦ What to do when you don’t have an updated SDS?

(product no longer made, manufacturer out of business, outside of US etc)

◦ Who reviews for any newly identified physical or health hazards?

Challenges for Implementation- New SDSs

From: sigma-aldrich.com/safety-center.html

This is a good reference for EHS professionals to check classifications and make label choices if MSDS is not available.

Classification Tables

http://www.labcluster.com/news4/30334_ghs_poster_eu.pdf

Classification Table- Codes

Questions?