Globally Harmonized System

(GHS): Compliance StrategiesDale Goss, MBA, MPH, CSPEORM Principal Consultantgossd@eorm.com; 408.790.9261 Date: 3/14/13

Agenda

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� What is the GHS

� OSHA / CAL-OSHA Timeline

� Transitioning Your Organization

� What Has to be Updated?

� Hazard Types, Classes, Categories

� Summary w/ Helpful Links

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What is the GHS?

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� United Nations’ (UN) Globally Harmonized System (GHS) of Classification and Labeling of Chemicals

� Worldwide initiative adopted in 1992

� Activities, preparation, and implementation varies by country

� GHS is not a regulation or standard

� OSHA adopted GHS elements into the HazComStandard in May 2012. “Right to Understand”

http://www.osha.gov/dsg/hazcom/hazcom-faq.html

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Current Labeling System (Caffeine Example)

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From Merck w/ modificationhttp://www.emdmillipore.com

LD50 oral: 261 mg/kg

Labeling Under GHS(Caffeine Example)

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From Merck w/ modificationhttp://www.emdmillipore.com

Where Should You Begin?

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Federal OSHA Timeline

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� Key implementation dates: http://www.osha.gov/dsg/hazcom/effectivedates.html

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Dec 1, 2013

• Employers must train employees on new pictograms, label elements & safety data sheet (SDS) format

June 1, 2015

• Chemical

manufacturers,

importers, and

select employers

must comply with all modified provisions of the final rule

• Except:

Dec 1, 2015

• Distributors shall not ship containers labeled by the chemical manufacturer or importer unless it has a GHS label

June 1, 2016

• Employers to update alternative workplace labeling and hazard communication programs

• Provide additional employee training for new hazards

What About Cal-OSHA?

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� State of California, Dept. of Industrial Relations, Memorandum (August 2012)– Board proposed to adopt federal regulations

� CAL-OSHA Public Hearing (November 2012)– Significant discussions. Effective date proposed to

be upon filing with the Secretary of State.

� How should California employers implement the new HCS?– If California does not have a system in place,

employers must follow Federal regulations

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Adobe Acrobat

Document

Adobe Acrobat

Document

Questions to Consider

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� Are you familiar with the standard(s)?

� Where are the facilities located?

� When was the written plan reviewed?

� What are the methods of delivering training?

� What role will internal/external vendors play?

� What recent business changes have/will occur?

� What resources are available?

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Best Management Practices

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� Complete a gap analysis evaluating:

– Accuracy of your chemical inventory

– How SDS are acquired & maintained

– How secondary chemical containers are labeled

– Alternative workplace labeling

– How you deliver (or plan to deliver) training

– How will you update the written program

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Complete A Gap Analysis

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� Transitioning the organization will take time

– Having a prioritized strategy is helpful

� EORM recommendation: “Full Phased Approach” vs. waiting for key deadlines

� Evaluate current methods/activities and how the organization defines select terminology

� Incorporate:

– Questions to Consider (Slide 9)

– Best Management Practices (Slide 10)

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Chemical Inventory & SDSs

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� How do you acquire/manage SDS?

� When was the last chemical inventory?

� How accurate is the inventory?

� Do you need to re-author any SDS?

� 30-year MSDS (SDS) requirement

– Various regulations require employers to maintain MSDS’/SDS’ after an exposure or incident involving exposure

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http://www.airliquide.com/

Classification of Hazards

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• Physical, Health, & Environmental

Hazard Types

• Refers to the nature of the physical, health or environmental hazard, such as flammable solid, carcinogen, acute toxicity, etc.

Hazard Classes

• Each hazard class contains five (5) hazard categories

Hazard Categories

Hazard Types & Classes

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Hazard Category Designation

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� Reference SDS for classification, pictogram, and signal word

� Hazard category may or may not have a pictogram indicating nature of the

hazard

Less Hazardous

NFPA Numerical Designation Concern

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� Reverse number order regarding hazard classification

� GHS rules use Category 1 – 5

– Lower the number, greater the hazard

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Less Hazardous

Train Affected Employees

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� Evaluate training and method of delivery– Training must be completed by December 1, 2013

– Review should include the new:

» Signal words and labeling

» Hazard pictograms

» SDS 16-section format

» Note: Dual pictograms training requirements (until regulation is fully phased)

� OSHA’s Model Training Program:http://www.osha.gov/dsg/hazcom/MTP101703.html

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Label Requirements

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Name, Address & Phone # of Manufacturer, Importer, or Responsible Party

Product Identifier: chemical identity of the hazardous substance. Needs to match SDS

Hazard Statement(s)

Precautionary Statement(s) There are four types: “prevention”, “response”, “storage”, and “disposal”

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)

Alternative Workplace Labels

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� Update Facility Labels and Signs

– Laboratory signs

– Secondary chemical containers

– Hazardous Waste Storage Areas

� Note: Local Fire Department

jurisdiction requirements for

exterior building signs

– NFPA Diamonds

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Finally: Update the Program

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� Integrate GHS changes into the written program

� HazCom Program elements: http://www.osha.gov/dsg/hazcom/solutions.html

� Communicate any ‘new hazards’ identified to employees

� Due June 1, 2016

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Audience Discussion

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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?

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Useful Links

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� OSHA GHS Fact Sheethttp://www.osha.gov/dsg/hazcom/HCSFactsheet.html

� OSHA GHS QuickCardshttp://www.osha.gov/dsg/hazcom/ghsquickcards.html

� Official UN GHS Website (Country by Country comparison)http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html

� Comparing GHS to Federal HazCom by Line Itemhttp://www.osha.gov/dsg/hazcom/ghoshacomparison.html#footnote1

� Classification, Labeling & Packaging (CLP) Regulationshttp://echa.europa.eu/legislation/classification_legislation_en.asp

� Shipping by Hazard Category, Signal Word, and Hazard Statementshttp://www.sitehawk.com/ghs_hazard_physical_content.html

© 2013 Environmental and Occupational Risk Management, Inc.

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Thank You

© 2013 Environmental and Occupational Risk Management, Inc.

Dale Goss, MBA, MPH, CSP

EORM Principal Consultant

gossd@eorm.com; 408.790.9261