Globally Harmonized System and the Hazard Communication …southernaerosol.com/Power...
Transcript of Globally Harmonized System and the Hazard Communication …southernaerosol.com/Power...
Globally Harmonized Systemand the Hazard Communication
Standard
What You Might Expect
PRESENTED BY:
Keith D. Hass
Assistant Area Director
Atlanta East Area Office
How We Got Here
• Commitment in the preamble to the final standard in 1983 to review the standard regularly to address international harmonization.
• Years of bilateral trade negotiations.
• International mandate adopted in 1992.
• Negotiations to complete the GHS in several international organizations for the next 10 years.
• OSHA chaired coordinating group
Hazard Communication
• Tuesday, September 12, 2006, ANPR to modify the Hazard Communication Standard to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)
What is an ANPR?
• An ANPR is a document in the Federal Register that describes what the Agency is working on, and gives the public an opportunity to provide input in the form of written comments.
• The US regulatory process includes a number of required activities, as well as analyses to support the process.
Regulatory Process
• Rulemaking Steps
– ANPR
– Notice of Proposed Rulemaking
• Public Comment Period
• Public Hearing
• Post-hearing Comment Period
– Final Standard
– Phase-in Period for Compliance
Analytical Requirements
• Economic Feasibility
• Technological Feasibility
• Paperwork Burden
• Impact on Small Businesses (Small
Business Regulatory Enforcement
Fairness Act process)
• Peer Review
Scope of GHS
• Four primary U.S. regulatory agencies
– OSHA, EPA, DOT and CPSC
• GHS designed to allow regulatory agencies to choose provisions –―building block approach‖
– OSHA would choose the provisions of the GHS that are necessary for the protection of employees, but would not adopt others that address other types of protection e.g. aquatic life protection
GHS Requirements
• Health, physical and environmental
hazard criteria for substances and for
classification of mixtures
• Provisions for communicating
information on labels (including
harmonized pictograms, hazard
statements, and signal words)
• A 16-section safety data sheet
Impact on OSHA
Requirements
• Hazard Communication Standard
includes the primary affected
requirements.
• OSHA has more requirements affected by
the GHS than other US agencies:
– Cover all acute and chronic hazards.
– Have requirements for labels and safety data
sheets.
– Cover over 7 million workplaces and 945,000
hazardous chemical products.
What That Means for HCS…
• The framework of the HCS will remain
the way it is currently promulgated, i.e.,
those provisions not affected by the
GHS will remain the same.
• Adoption of the GHS by OSHA would
affect general industry, construction
shipyards, long shoring and maritime.
• The scope of GHS very similar to HCS.
• However, it does not include requirements for a written hazcom program or for employee training.
• OSHA will maintain training requirements.
• OSHA also expects to propose some additional training to ensure understanding of the new approach regarding labels and SDSs in the GHS.
What That Means for HCS…
Health Hazards
• Both the HCS and GHS have a broad range of health effects, including both acute and chronic effects.
• For HCS, any type of adverse health effect that is reported and substantiated by a scientific study is covered.
• Under GHS, hazard classes are generally sub-divided into categories of hazard.
• The definitions of hazards are much more specific and detailed than what is in the HCS.
What will OSHA adopt??
• Scope will likely be consistent with the
HCS to the greatest extent possible.
• Therefore, it is likely OSHA will adopt
all of the health and physical hazard
criteria. However, the Agency may not
adopt all categories of each criterion.
Example: Acute Toxicity
• OSHA covers acute toxicity in the current rule.
• Since the GHS includes criteria for consumer protection in addition to worker protection, the criteria are more extensive than HCS.
• It is not likely that OSHA will adopt all of the categories of acute toxicity when aligning with the GHS.
Health Hazards
HSC
• Carcinogens
• Toxic or highly toxic agents (all routes of entry)
• Reproductive toxins
• Irritants
• Corrosives
• Sensitizers
• Hepatotoxins
• Nephrotoxins
• Neurotoxins
• Agents which act on the hematopoietic system
• Agents which damage the lungs, skin, eyes, or mucous membranes
GHS
• Acute toxicity (any route of entry)
• Skin corrosion/irritation
• Serious eye damage/eye irritation
• Respiratory or skin sensitizer
• Germ cell mutagenicity
• Carcinogenicity
• Reproductive toxicity
• Specific target organ systemic toxicity--single exposure
• Specific target organ systemic toxicity--repeated use
• Aspiration hazard
Physical Hazards
• With regard to physical hazards, the
current definitions in the HCS are
drawn from other standards that
address such chemicals (e.g.,
flammable chemicals), or from what
were the DOT criteria for physical
hazards at the time OSHA promulgated
the HCS.
• DOT has since changed their criteria
Physical Hazards
HSC
• Combustible liquid
• Compressed gas
• Explosive
• Flammable (aerosol, gas, liquid, solid)
• Organic peroxide
• Oxidizer
• Pyrophoric
• Unstable (reactive)
• Water-reactive
GHS
• Explosives
• Flammable (aerosol, gas, liquid (including combustible liquid),
• solid)
• Oxidizing (liquids, solids, gases)
• Gases under pressure
• Self-reactive substances and mixtures
• Pyrophoric (liquid, solid)
• Self-heating substances and mixtures
• Substances and mixtures which in contact with water emit flammable
• gases
• Organic peroxide
• Corrosive to metals
Physical Hazards
• One issue of concern is whether OSHA
should also propose to change the physical
hazard definitions in other standards e.g.
definition of flammable liquids in the
flammable liquids standard
• What is the impact beyond classification and
labeling?
• Area that needs to be further explored in
terms of impact and possible consequences.
Labeling
• The HCS minimal information on labels
• At the time the standard was promulgated, OSHA focused on requiring information that was not generally present on most labels in use by industry.
– e.g. identity that could be traced to more detailed information, and specific information about both the health and physical hazards.
• Performance – oriented approach
Labeling
• The HCS would change to adopt the
label provisions of the GHS for
harmonized pictograms, hazard
statements, and signal words.
• Identification of the chemical and
supplier and precautionary information
would also be included.
Labeling Advantages
– May improve communication for those
who are not functionally literate, or who
are not literate in the language written on
the label.
– Having the core information developed
already, translated into multiple
languages, and readily available, will
eliminate the burden of chemical
manufacturers and importers developing
and maintaining their own such systems.
GHS Labeling
• Symbols (hazard pictograms): Convey
health, physical and environmental
hazard information, assigned to a GHS
hazard class and category.
GHS Labeling
• Signal Words: "Danger" or "Warning"
are used to emphasize hazards and
indicate the relative level of severity of
the hazard, assigned to a GHS hazard
class and category.
GHS Labeling
• Hazard Statements: Standard phrases
assigned to a hazard class and
category that describe the nature of the
hazard. e.g.
– Fatal if swallowed
– Toxic if swallowed
– Harmful if swallowed
GHS Labeling
• Other GHS label elements include:
– Precautionary Statements and Pictograms:
Measures to minimize or prevent adverse effects.
– Product Identifier (ingredient disclosure): Name or
number used for a hazardous product on a label or
in the SDS.
– Supplier identification: The name, address and
telephone number should be provided on the label.
– Supplemental information: non-harmonized
information.
GHS Labeling
Safety Data Sheets
• The HCS specifies what information must be included on the MSDS, but does not specify a format or order of information.
• Chemical manufacturers in the U.S. developed a voluntary industry consensus standard that included an order of information for safety data sheets (ANSI Z400.1).
• In negotiating the GHS, it was decided that this format should be adopted there as well.
Safety Data Sheets
• The HCS would likely be modified to include
the GHS order of information reversing the
order of sections 2 and 3 so the hazard
information appeared earlier in the sheet
than information on chemical composition.
• Adopt title descriptions.
• However, it would not include mandatory
requirements for sections dealing with
issues that are not under OSHA’s
jurisdiction, e.g., transport and environment.
Safety Data Sheets
HCS
• Identification of the chemical or hazardous ingredients of a mixture
• Physical and chemical characteristics
• Health hazards, including signs, symptoms, and medical conditions that could be aggravated by exposure
• The primary routes of entry
• The OSHA permissible exposure limit, ACGIH Threshold Limit Value, and any other recommended exposure limits
• Whether the chemical is considered to be a carcinogen by OSHA, the International Agency for Research on Cancer, or the National Toxicology Program
• Precautions for safe handling and use
• Control measures
• Emergency and first aid procedures
• Date of preparation of the safety data sheet
• Contact information for the responsible party
GHS
• Identification
• Hazard identification
• Composition/information on ingredients
• First aid measures
• Firefighting measures
• Accidental release measures
• Handling and storage
• Exposure controls/personal protection
• Physical and chemical properties
• Stability and reactivity
• Toxicological information
• Ecological information
• Disposal considerations
• Transport information
• Regulatory information
• Other information
Environmental Information
• GHS includes criteria for classifying
aquatic toxicity.
• The GHS SDS also includes information
related to the environment.
• OSHA has no authority in these areas
and therefore will not be adopting the
parts of the GHS that are relevant to
environmental protection.
Other Standards Also
Affected
• Will likely need to change hazard
communication provisions in
substance-specific standards to be
consistent.
• May also need to address parts of other
standards that have criteria for hazard
definitions, such as flammable liquids.
Information Needed from the
Public
• Assistance in defining the scope of the
changes needed:
– Requesting information about the numbers
of products to be reevaluated under the
new criteria, and new labels, SDSs
prepared
– Also information about the time it takes to
do these activities and the qualifications of
those who perform them
Other Input
• OSHA will need to assess the costs and
benefits and will be soliciting
information from the public on these
topics.
• The availability of electronic tools and
their relationship to compliance
activities will also need to be assessed.
Timing
• Labels and SDSs are normally updated
on a regular cycle.
• OSHA wants to establish a phase-in
period for compliance that will take
advantage of this regular cycle and
reduce costs as a result.
• Input on updating time frames is
needed.
Other Phase-In Issues
• OSHA will consider other suggested
approaches to phasing in if supported
by evidence:
– The Europeans are considering phasing in
substances first and then mixtures—will
this work in the US?
– What other approaches to staging or
phasing would be effective and reduce
burdens?
Technical Issues
• Input will also be requested on any
technical GHS issues that need to be
considered in implementation.
• One example would be the appropriate
categories of acute toxicity to adopt.
• Another would be to suggest any
hazards that might not be adequately
covered.
Compliance Assistance
• OSHA wants to identify what
compliance assistance tools would
facilitate the transition to the GHS so
such outreach can be made available
when the rulemaking is completed.
• Public suggestions will be sought to
identify these tools.
HCS Conclusion
• Greatest impact on chemical manufacturers, importers, and employers who produce or distribute hazardous chemicals as currently covered under the HCS.
• More consistency and better communication
• Significant phase-in period
• Frequently asked questions document
www.osha.gov
Call for Additional Assistance
• Keith Hass (770) 493-5412
• Jonathan Worrell
Compliance Assistance Specialist
(770) 493-5400