Introduction to OSHA GHS (a.k.a. Hazcom 2012)southernaerosol.com/Power Point/Fall 2012/SATA Fall...

Introduction to OSHA GHS (a.k.a.

Hazcom 2012)

SATA Fall Meeting 2012

Mike P. Moffatt

Nexreg Compliance

Nexreg Compliance Inc. http://www.nexreg.com [email protected] (866)361-3032

http://www.nexreg.com/

mailto:[email protected]

Coverage

- Very basic, very high level. Won’t get too

into the specifics.

- We will have webinars RE: specific issues

and industries. If there is an issue you

would like covered, please e-mail

[email protected]





Upcoming Webinars

E-mail [email protected] for an invite.

• Sections/Subsections of the SDS (MSDS)

• Classifications, Symbols and Statements

• Aerosol Label Issues

• Hazards Not Otherwise Classified (HNOCs)





What is GHS?

- U.N. Initiative: Globally Harmonized

System of Classification and Labelling of

Chemicals (GHS)

- Harmonized

- Classification Criteria

- Safety Data Sheets (SDSs)

- Label Elements




Building Block Approach

Purple Book – Up to 4th Revision.

- 3 Haz Groups: Health, Physical, Enviro.

- 28 classes (10 H, 16 P, 2 E)

- Categories (under class)

e.g. Ph: Flammable Aerosol, Category 2





- 2 Signal Words (Danger, Warning)

- 72 ind., 17 comb. Hazard Statements

- 105 ind., 33 comb. Precautionary Statem.

- Standardized 16 section SDS

- 9 Pictograms (non-transport)





• Each jurisdiction has adopted some building

blocks but not others (and list is different from

jurisdiction to jurisdiction).

• Each jurisdiction has adopted non-GHS rules

(EU SDS Format 453/2010, Prop 65, etc.) which

must also be followed.

GHS IS NEITHER GLOBAL NOR HARMONIZED




Harmonization

• You CANNOT simply take a ‘GHS’ SDS

that is for use in Europe and use it in the

U.S. Will not be compliant – open

company up to OSHA/civil liability.

• It is often possible to have a single SDS

authored to cover multiple jurisdictions

(U.S., Ireland, etc.), but not always.




Problems with an SDS for

‘Everywhere’ • Must be authored to the strictest country’s

requirements for each rule. Makes products

looks overly hazardous.

• Strictest jurisdiction approach issue in the US,

as means one loses ‘trade secrets’ ability.

• Occasionally rules contradictory (making

harmonization impossible).




U.S. Situation

Will still be called the Hazard Communication

Standard (HCS). To avoid confusion, OSHA

proposes the informal name of Hazcom 2012.

Based on (but far from identical to) 3rd (not 4th)

edition of the GHS Purple Book.




Hazcom 2012

Hazcom 2012 covers:

– Safety Data Sheets (formerly MSDSs)

– Industrial Product Labels

Hazcom 2012 does not cover:

– Consumer Product Labels (regulation

unchanged)




Where We Are in the Process

U.S.

- In a transition period, where the old Hazcom

rules governing MSDSs and industrial labels can

be followed or the new Hazcom 2012 can be

followed.

Rule at:

http://www.osha.gov/dsg/hazcom/index.html





Hazcom 2012 Key Dates

- December 1, 2013 Employees must be

trained on SDSs and labels.

- June 1, 2015 Compliance with final rule

for SDSs and labels. (Same date as EU

for mixtures)

- December 1, 2015 Distributors must stop

shipping products with “old” labels.




OSHA GHS (a.k.a. Hazcom 2012)

for Absolute Beginners

SDSs Hazcom 2012




Hazcom 2012 SDSs

– Hazcom 2012 introduces a 16-section SDS.

– Note the sections/subsections differ

somewhat from the old ANSI standard 16-

section MSDS (having a 16-section MSDS

does not make one Hazcom 2012 compliant)




Hazcom 2012 SDSs

– There are a list of headings and subheadings

that are required on a Hazcom 2012 SDS.

These are not to be deleted if there is no

information/they are not applicable.

– Instead it is required to fill in the required

information (which may be simply writing not

available).






Industrial Labels in Hazcom 2012




Label Pictograms

NOTE: Colour red mandatory for all Hazcom 2012 label pictograms.

NOTE: Not allowed to have blank red diamonds or fill them in with ‘THIS DIAMOND INTENTIONALLY LEFT BLANK’ or cross them out.




Font Size and Placement Rules

- Almost nonexistent. A surprising lack of

detail in the regulation.

- We expect OSHA to release a labeling

guidance document sooner rather than

later.




What are the Rules?

- Red diamond border must be in red.

- Fonts and symbols should be legible, but

this is not defined.

- Precautionary statements must be kept all

together.




What are the Rules?

- No rules on where on the container the

information should be placed.

- Information can be kept in a self-contained

box (similar to WHMIS) or spread around

the container, with symbols in one area

and statements in other (similar to CCCR).




Required Statements, Symbols,etc.

- Statements, symbols, signal words, etc.

come from classification of product under

classes and categories.

- We will discuss one of the classes that

provide special challenges to aerosols –

this is not an exhaustive list.






Classification Example - Hazcom 2012




Flammable Aerosols

The classes of Flammable Aerosol are as

follows:

– Category 1: Extremely flammable aerosol

– Category 2: Flammable aerosol

– N/A




Flammable Aerosols – No Data

“Aerosols not submitted to the flammability

classification procedures in this Appendix

shall be classified as extremely flammable

(Category 1)”.




Flammable Aerosols – Category 1

Separate criteria for:

– Spray Aerosols

– Foam Aerosols





Spray Aerosols Flammable components 85%

AND

the heat of combustion is 30kJ/g

AND

in the ignition distance test, ignition occurs

at a distance 75cm (29.5 in).





Foam Aerosols Flammable components 85% AND


AND ONE OF THE FOLLOWING

– Flame height 20cm (7.87 in) and the flame

duration 2s.


duration 7s.

–





If category 1 criteria not met, test for

category 2.

Separate criteria for:

– Spray Aerosols

– Foam Aerosols





Spray Aerosols Flammable components >1% AND



– In the ignition distance test, ignition occurs at

a distance 15cm (5.9 in).





Spray Aerosols Flammable components >1% AND



– In the enclosed space ignition test, the time

equivalent 300s/m^3 OR the deflagration

density 300g/m^3.





Foam Aerosols Flammable components >1% AND


AND


duration 2s.




Difference in Elements Between

the Two Categories SIGNAL WORDS:

Cat. 1: DANGER

Cat. 2: WARNING

HAZARD STATEMENT:

Cat. 1: Extremely Flammable Aerosol

Cat. 2: Flammable Aerosol




Identical Elements For Both

Categories PRECAUTIONARY STATEMENTS:

– Keep away from heat/sparks/open flames/hot

surfaces. - No smoking. Chemical

manufacturer, importer, or distributor to

specify applicable ignition source(s).

– Pressurized container: Do not pierce or burn,

even after use.




Identical Elements For Both

Categories PRECAUTIONARY STATEMENTS:

– Do not spray on an open flame or other

ignition source.

– Protect from sunlight. Do not expose to

temperatures exceeding 50° C/122° F.

SYMBOL

– GHS02






Industrial vs. Consumer Labels




When is a Product an Industrial

Product? - Difficulty: The dividing line between consumer

products and industrial products not clear.

- e.g. Product sold at a Big Box retailer that is

used both at home and by contractors.





Product? - Rule of thumb: A dual (home, business)

product requires an industrial label when both

apply:

1. It is used in the workplace.

2. It is used by a worker far more frequently

than would be used by the average

consumer.





Product? On a product sold in a retail store, the onus is

on the workplace to ensure that the product is

labeled workplace use, not the manufacturer

(otherwise everything would need an industrial

label, as you cannot predict how often/where

every single user would use the product)





Product? The question of whether or not to include a

workplace label (along with a consumer label)

on one of these products is essentially a

marketing decision, not a regulatory one:

Will we gain/lose more sales from having it on

vs. not having it on.




Options

1. Include the industrial label on the product.

2. Put a statement on the product such as: “For

SDS and Hazcom 2012 label please visit

[website]. Can include a PDF of the

workplace label which can be printed on an

Avery label by the workplace.






Next Steps




To Dos – In Order of

Importance 1. Budget and develop a training plan for

employees. December 1, 2013 will

come quickly.





Importance 2. Determine how you will print your

product labels to be in compliance with

the new standard, specifically the red

diamond and the requirement that there

be no blank diamonds on the label.





Importance 3. Determine how you will author your SDSs

and labels and set aside a budget to do so.

OSHA estimates cost (software + labour) of

SDS authoring to be $406 per SDS for large

businesses (500+ employees) to $462 per

SDS for small businesses (fewer than 99

employees).





Importance 4. If authoring in house, ensure software (if

using) is compliant with Hazcom 2012

standard, author trained in new regulation,

and that the necessary substance level

classifications are obtained.





Importance 4 (continued) – Sources of data can include:

- Publicly available EU sources, such as

REACH registered substances:

http://echa.europa.eu/web/guest/information-on-

chemicals/registered-substances

- Private databases, such as Chemadvisor’s

LOLI.


http://echa.europa.eu/web/guest/information-on-chemicals/registered-substances










Importance 5. Stay up-to-date

U.S. Government:


Nexreg Free News:

http://www.nexreg.com/regulatorynews

http://www.hazcom2012.com (Coming

soon!)



http://www.nexreg.com/regulatorynews

http://www.hazcom2012.com/



Ten Action Items to Start Today

6. Most importantly:

DON’T PANIC




Any Questions?




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Introduction to OSHA GHS (a.k.a. Hazcom 2012)southernaerosol.com/Power Point/Fall 2012/SATA Fall...

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