The Globally Harmonized System (GHS) for Hazard …c.ymcdn.com/sites/ · · 2013-07-17Tom...
Transcript of The Globally Harmonized System (GHS) for Hazard …c.ymcdn.com/sites/ · · 2013-07-17Tom...
Development of a Worldwide System for Hazard Communication
Tom Hawkinson, CIH, CSP
Global EHS Manager, The Toro Company
The Globally Harmonized System (GHS)
for Hazard Classification and Labeling
What is the GHS?
A common and coherent approach to defining and
classifying hazards, and communicating information on
labels and safety data sheets.
Target audiences include workers, consumers, transport
workers, and emergency responders.
Provides the underlying infrastructure for establishment
of national, comprehensive chemical safety programs.
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Why is the GHS needed?
No country has the ability to identify and specifically
regulate every hazardous chemical product.
For example, in the United States, there are an estimated
650,000 materials.
A uniform system of hazard communication will help
inform all users of a material.
3
Major Existing Systems
UN Transport Recommendations
European Union (EU) Directives on Substances and
Preparations (now including REACH)
Canadian Requirements for Workplace, Consumers and
Pesticides
US Requirements for Workplace, Consumers, Pesticides, and
Transportation
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Principles Of Harmonization
Protections will not be reduced; uniform messages will be key.
All types of chemicals will be covered; will be based on intrinsic properties (hazards) of chemicals.
All systems will have to be changed.
6
EU Chemical Regulation
EU Parliament Directive (DSD/DPD)
Transposition by member states into country legislation
Enforcement responsibility of member state
EU Regulation
European Chemical Agency (ECHA)
Directly adopted, force of law throughout EU
Key Regulations
REACH ( Registration, Evaluation, Authorisation and Restriction of
Chemical substances)
CLP – Defines GHS implementation in the EU (Classification, Labeling
and Packaging)
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Timeline for Harmonization
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OSHA GHS GHS Trg Labels/SDS
REACH PreReg >1000 TPY >100 TPY >1TPY
Year 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
CLP Substances DSD DSD/CLP CLP
CLP Mixtures DPD
Guidance & Outreach
• Press Release: US Department of Labor's OSHA publishes final
rule to update the Hazard Communication Standard (HCS)
• Guidance
» OSHA Briefs
» Fact Sheet
» Quick Cards
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a) Purpose
HazCom 1994
• All hazards to be evaluated.
• Comprehensive hazard
communication program to
transmit information.
• Preempt state laws.
HazCom 2012
• All hazards to be classified.
• Other provisions the same,
except OSHA added that the
rule is consistent with Revision
3 of the GHS.
• Slight clarifying modification
was made to the language
regarding preemption.
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b) Scope and Application
HazCom 1994
• All chemicals known to be
present are covered.
• Practical accommodations for
special situations.
• Addresses interface with other
Federal laws.
HazCom 2012
• Minimal changes except to
conform terminology, and
remove reference to current
Appendix E which has been
deleted from the standard and a
clarification on Federalism.
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c) Definitions
HazCom 1994
• Includes specific definitions for terms
used in the standard, as well as all
physical hazards.
HazCom 2012
• Physical hazard definitions removed
from paragraph (c), and placed in a
new Appendix B on physical hazard
classification criteria.
• Following terms are also deleted:
flashpoint (methods included in
Appendix B), hazard warning, material
safety data sheets.
• Some definitions are revised to be
GHS-consistent.
• New definitions added for
classification.
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d) Hazard Classification
HazCom 1994
• Performance-oriented
» Definitions in paragraph (c),
Appendices A and B
» Appendix B—parameters for
evaluating data
» “Floor” of chemicals
considered hazardous
» “One study” rule
» Standardized mixture cut-off
rules
HazCom 2012
• Specific and detailed
» Concept of “classification” vs.
determination in current rule
» Each hazard class has detailed
criteria to apply to data on
the chemical
» No floor; based on weight of
evidence
» Mixture rules are specific to
each hazard class
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Hazard Classification
• Each physical or health hazard is a “hazard class” (e.g.,
Carcinogenicity is a hazard class).
• A “hazard class” may be sub-divided in the criteria into several
“hazard categories” based on the degree of severity of the hazard.
• Placing a chemical into a “hazard class” , and where necessary, a
“hazard category”, is the concept of classification—determining
not only the hazard, but also the severity of the effect.
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Hazard Classification, cont. • Manufacturers are still responsible for determining the hazards of
the chemicals they produce or import.
• Classification (similar to hazard determination) is based on the full
range of available information. The procedures for determining if
the manufacturer has properly performed the hazard classification
are provided in Appendix A (health) and Appendix B (physical).
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Health Hazards
Hazard Class Hazard Category
Acute Toxicity 1 2 3 4
Skin Corrosion/ Irritation 1A 1B 1C 2
Serious Eye Damage/ Eye Irritation 1 2A 2B
Respiratory or Skin Sensitization 1
Germ Cell Mutagenicity 1A 1B 2
Carcinogenicity 1A 1B 2
Reproductive Toxicity 1A 1B 2 Lactation
STOT – Single Exposure 1 2 3
STOT – Repeated Exposure 1 2
Aspiration 1
Simple Asphyxiants Single Category
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Physical Hazards Hazard Class Hazard Category
Explosives Unstable Explosives Div 1.1 Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6
Flammable Gases 1 2
Flammable Aerosols 1 2
Oxidizing Gases 1
Gases under Pressure
Compressed Gases
Liquefied Gases
Refrigerated Liquefied Gases
Dissolved Gases
1
Flammable Liquids 1 2 3 4
Flammable Solids 1 2
Self-Reactive Chemicals Type A Type B Type C Type D Type E Type F Type G
Pyrophoric Liquids 1
Pyrophoric Solid 1
Pyrophoric Gases Single category
Self-heating Chemicals 1 2
Chemicals, which in contact with
water, emit flammable gases 1 2 3
Oxidizing Liquids 1 2 3
Oxidizing Solids 1 2 3
Organic Peroxides Type A Type B Type C Type D Type E Type F Type G
Corrosive to Metals 1
Combustible Dusts Single category 19
Hazard Statements
A single harmonized hazard statement for each level of
hazard within each hazard class
Example: Flammable liquids
Category 1: Extremely flammable liquid and vapour
Category 2: Highly flammable liquid and vapour
Category 3: Flammable liquid and vapour
Category 4: Combustible liquid
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Hazards not Otherwise Classified
• This definition was added to ensure that hazards currently covered
by HCS continue to be covered.
• Information will be required on the safety data sheets in Section 2.
• Hazard information on the label, is not mandatory, but can be
provided under supplementary information.
• Such hazards must also be addressed in worker training.
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Simple Asphyxiant and Pyrophoric Gas
• “Simple asphyxiant” means a substance or mixture that displaces
oxygen in the ambient atmosphere, and can thus cause oxygen
deprivation in those who are exposed, leading to unconsciousness
and death.
» Label: Warning. May displace oxygen and cause rapid suffocation.
• “Pyrophoric gas” means a chemical in a gaseous state that will
ignite spontaneously in air at a temperature of 130 degrees F (54.4
degrees C) or below.
» Label: Danger. Catches fire spontaneously if exposed to air.
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Combustible Dust
• Combustible dust is covered separately from HNOC, but is not
specifically defined.
• Guidance for defining combustible dust is to be taken from
existing documents, including the directive for the National
Emphasis Program; the NFPA standards also provide useful
information.
• Combustible dust must be addressed on labels where appropriate:
» Warning. May form combustible dust concentrations in air.
» Paragraph (f)(4) may apply to materials shipped in solid form, that create
combustible dust when processed.
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e) Written Hazard Communication Program
HazCom 1994
Employers must have a
written program describing
how the rule will be
implemented, including a list
of hazardous chemicals,
methods for informing
employees about non-routine
tasks.
HazCom 2012
No changes.
Employers will have to make
sure the program is current
when the new provisions are
implemented (e.g., list of
hazardous chemicals may have
to be updated).
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f) Labels and Other Forms of Warning
HazCom 1994
• Shipped containers to be labeled
with identity, appropriate hazard
warnings, and responsible party.
• Performance-oriented, specifics
left to discretion of chemical
manufacturer or importer.
HazCom 2012
• Shipped containers to be
labeled with product
identifier; signal word; hazard
statement(s); pictograms;
precautionary statements; and
responsible party.
• Specifies information by
hazard class and category.
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OSHA Training Requirements
The first compliance date of the revised HCS
is December 1, 2013. By that time employers
must have trained their workers on the new
label elements and the SDS format.
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OSHA Training Requirements
• GHS has the same objectives as HazComm • Convey hazard • Communicate precautions • Guide use, storage and disposal
• GHS has different methods • Expands the hazard categories • Uses standardized definitions and phrases for hazard
description • Uses standardized (but different) label elements • Uses a standardized SDS format with additional
information requirements (not all used by OSHA)
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Tiered Approach to Classification
Use test data for the mixture (when available)
Use bridging principles, if applicable
For health and environmental hazards, estimate hazards based on the known ingredient information
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Tiered Approach to Classification
Bridging Principles
DNEL (Derived No Effect Level/Do Not Exceed Level)
QSAR (Qualitative Structural Activity Relationships)
Codified in REACH
Applied to new materials, mixtures or materials where not
toxicology has been done
Calculation of DNEL can be quite different than national
occupational standards
Must specify protections for anticipated uses (9 pg IPA MSDS to
103 pg SDS)
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Pictogram Shape and Color
For transport, pictograms will have the background and symbol colors currently used.
For other sectors, pictograms will have a black symbol on a white background with a red diamond frame. A black frame may be used for shipments within one country.
OSHA permits this for internal labels
Where a transport pictogram appears, the GHS pictogram for the same hazard should not appear.
OSHA recently revised this to allow both
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Workplace Labeling • OSHA is maintaining the approach used in the current HCS that
allows employers to use workplace-specific labeling systems as
long as they provide the required information.
• However, such workplace label systems may need to be updated to
make sure the information is consistent with the new
classifications.
• NFPA/HMIS Systems
» (ratings systems v. classification)
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Health Standards • Asbestos (1910.1001; 1926.1101;
1915.1001)
• 13 Carcinogens (1910.1003)
• Vinyl Chloride (1910.1017)
• Inorganic Arsenic (1910.1018)
• Lead (1910.1025; 1926.62)
• Chromium (VI) (1910.1026; 1926.1126;
1915.1026)
• Cadmium (1910.1027; 1926.1127)
• Benzene (1910.1028)
• Coke Oven Emissions (1910.1029)
• Cotton Dust (1910.1043)
• 1,2-dibromo-3-chloropropane
(1910.1044)
• Acrylonitrile (1910.1045)
• Ethylene Oxide (1910.1047)
• Formaldehyde (1910.1048)
• Methylenedianiline (1910.1050; 1926.60)
• 1,3-Butadiene (1910.1051)
• Methylene Chloride (1910.1052)
• Occupational exposure to hazardous
chemicals in laboratories (1910.1450)
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Safety Standards • Flammable Liquids (1910.106; 1926.52)
• Spray finishing using flammable and combustible materials (1910.107)
• Process safety management of highly hazardous chemicals (1910.119; 1926.64)
• Hazardous waste operations and emergency response (1910.120; 1926.65)
• Dipping and coating operations: Coverage and definitions (1910.123)
• General requirements for dipping and coating operations (1910.124)
• Additional requirements for dipping and coating operations that use flammable liquids or
liquids with flashpoints greater than 199.4 °F (93 °C) (1910.125)
• Welding, Cutting, and Brazing (1910.252)
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Role of the SDS in the GHS
The Safety Data Sheet (SDS) should provide
comprehensive information about a chemical substance or
mixture.
Primary Use: The Workplace
Employers and workers use the SDS as a source of information
about hazards and to obtain advice on safety precautions.
SDS can be requested by consumers and may be required by supply
chain partners
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SDS Format: 16 headings
1. Identification
2. Hazard(s) identification
3. Composition/information on ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure control/personal protection
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Format: 16 headings (cont.)
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information
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Toro Implementation of GHS Training
Several approaches employed
Key issues
Identifying hazardous materials on site
Providing MSDS/SDS index and access
Delivering training
Keeping adequate records
HazComm consistently one of OSHA’s top ten citations
New requirements will move it to the top of the list
Current challenge: assure everyone is trained by Dec 1, 2013
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Toro Implementation of GHS Training
Strategies
Online training using ResourceNOW
Content current for GHS training
Delivery tests student and delivers certificate
Learning Management System pushes training notice and records
completion
Features include:
Customizable content
Online delivery
Library of resources
LMS
Some Spanish language training
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Toro Implementation of GHS Training
Strategies
Some sites prefer classroom delivery
Language/educational level issues with standard content
Shut-downs and Training Days allow for completion in a single timeframe
Poor support for electronic learning
Inadequate technological equipment base
Inadequate technological skillset among workers
Inadequate support to implement process
Regardless of strategy:
Assure everyone who needs training receives it
Keep good records/follow up with stragglers
Assure MSDS/SDS collection current, indexed and available
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