HazCom 2012 Changes Introduced by the GHS: Upcoming Changes and Your Responsibilities

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GHS Changes to Hazard Communication: Upcoming Changes and Your Responsibilities

Transcript of HazCom 2012 Changes Introduced by the GHS: Upcoming Changes and Your Responsibilities

GHS Changes to Hazard Communication:

Upcoming Changes

and Your

Responsibilities

Changes Will We Cover Differences between MSDS & GHS SDS

New Label Format

Additional Hazardous Chemicals Categories

Potential Points of Confusion

The GHS replaces MSDS with new Safety Data Sheets (SDS)

GHS Safety Data Sheet Hazard Communication Standard of SDS had 9 sections

New GHS has 16 specific sections

Consistent with ANSI format, familiar to many employees

Section 2 delivers information up-front

Some Sections are not enforced by OSHA because they are enforced by other regulatory bodies

The 16 SDS SectionsSection 1. Chemical Product & Company InformationSection 2. Hazards IdentificationSection 3. Composition/Information on IngredientsSection 4. First Aid MeasuresSection 5. Fire Fighting MeasuresSection 6. Accidental Release MeasuresSection 7. Handling and StorageSection 8. Exposure Controls/Personal ProtectionSection 9. Physical and Chemical PropertiesSection 10. Stability and ReactivitySection 11. Toxicological InformationSection 12. Ecological Information*Section 13. Disposal Considerations* * Not Enforced by OSHASection 14. Transport Information*Section 15. Regulatory Information*Section 16. Other Information

The GHS also updates labels

Label Elements

1) Product Identifier

2) Precautionary Statements

3) Hazard Statements

4) Signal Word

5) Hazard Pictogram Red borders, black symbol

6) Supplementary info

Let’s take a closer look at that label…

The GHS adds new chemical categories

Additional Hazardous Chemical Categories

1. Pyrophoric gases

2. Simple Asphyxiants

3. Combustible Dusts

Now Required on your SDS

Potential Points of Confusion during the GHS Transition

Points of Confusion: Who is Responsible for Updating your MSDS?

NFPA Codes on HazCom Labels…

?

?

Updating MSDS: Whose Responsibility is it?

Updating MSDSs If you are a manufacturer, distributor or importer you

must re-author your SDSs

It is the responsibility of your supplier to supply you with the most up-to-date MSDSs or SDSs they have authored

Two exceptions:

1. If you have not recently purchased an item from your supplier…

It is your responsibility to check in with them for the most updated version.

2. If you are shipping a finished product internationally…

It is your responsibility, not your domestic supplier’s, to author the country-specific GHS compliant SDS

GHS Implementation Your Responsibilities

1. Re-Classify your Chemicals

2. Re-author your SDSs

3. Generate GHS-compliant Labels

4. Train your Employees

Hazards Classification GHS Uses 3 Hazard Groups

Health Hazards- Dangers to human health

-10 Health Hazards

Physical Hazards- Damage to the body

- 16 Physical Hazards

Environmental Hazards

- Not under OSHA jurisdiction

- Danger to environment

- 3 Environmental Hazards

Hazard Group

Different types of hazards e.g. ‘Gases under pressure’ = class in Physical Hazards

Class

Category

Health, Physical or Environmental

Hazard Statement

Subsections of classesAssigned numbers/lettersCategory 1 = most hazardous

Standardized statementDescribes hazard category

The Importance of Classification Reliability

Best to use the two-tiered approach: 1) Have the most accurate raw chemical

data about your materials

2) Reference and compare multiple regulatory resources before making any final determinations

Classification: Reliability The key here is balance - not so many as SDS

takes too long to author, but enough to classify with confidence

Consult 3 to 5 trustworthy sources Use those same sources each time   Recommended: CLP, ECOTOX, RTECS, Sigma

MSDS, HSNO CCID

 

Vendor Communication

Vendor Communication The GHS Implementation makes communicating

with your vendors essential and urgent

But obtaining chemical info from vendors can be challenging

Goal is to avoid unrealistic conservative classifications

Risk Management

Risk Management Technique 1:

Ensure SDS Accessibility Centralize documents – single digital

database

Tags and other metadata to make queries/searches easier

Accessibility from mobile devices/tablets/laptops

Risk Management Technique 2:

Ensure Fastest Possible SDS Retrieval

Ease of user interface and searching

Respond to emergencies

Mobile App for fast retrieval

PS: ERA has a mobile

app specifically for

finding and retrieving

your SDSs.

Most businesses are turning to SDS Authoring Software to get them through the GHS transition without the stress of deadlines, loss of productivity, and interruptions to other EH&S reporting obligations.

SDS Authoring Software from ERAEnvironmental Management Solutionsis the most accurate,cost effective, and fast solution available.

Twenty years providing solutions for chemical compliance.

Award-winning team and award-winning software.

Exclusive partnerships with major chemical & coating manufacturers to get superior data (AkzoNobel, Sherwin Williams, Du Pont, and many more).

Want to learn more about the risks the GHS presents to your business?

Download your Free Guide:

Business Risks and Opportunities Associated with the GHS Transition

Learn more:

www.era-environmental.com

Email us: [email protected] us: 1-866-493-6409

Connect with us:@ERAenvironment

Thank youAny questions? Email Us at: [email protected]