New Chemical Hazard Communication StandardGlobally Harmonized System of Classification and Labeling of Chemicals, WAC 296-901-140
Overview of GHS and changes to the standard
What is the GHS?
Harmonized criteria for classifying substances and mixtures according to their health, environmental and physical hazards.
Harmonized hazard communication system including requirements for labeling and safety data sheets (SDS).
Target audience - workers, employers, consumers, transport workers, emergency responders.
http://bit.ly/LRVdsf
Agencies Involved with the GHS
Federal Washington State
DOT WSDOT
OSHA L&I / DOSH
EPA DOE & WSDA
CPSC
Dark green: Countries/regions that have already implemented GHS. Light green: Countries/regions where GHS is voluntary. Yellow: Countries/regions that are in the process of implementing GHS. Blue: Countries/regions where GHS is not implemented or not available.
OSHA’s “HazCom 2012” Standard
Published March 26, 2012
Conforms to the GHS, Rev. 3
Changes to:– Hazard classification
– Label content
– Safety Data Sheet content (mandatory 16 section SDS, % required)
Stay tuned . . .
The GHS is updated on a two year cycle.
Recent updates have mostly been text clarifications.
Future updates of the Chemical Haz Com standard may be necessary.
WISHA’s new GHS-based
Hazard Communication Standard
Effective April 15, 2013
Substantially identical to OSHA’s standard
Phase-in schedule:– During the transition period, there is the option to comply with
the applicable requirements in the existing rules, or the requirements in the new rule, or both.
– June 1, 2014: ERs train EEs on Safety Data Sheet (SDS) format and new label elements.
– June 1, 2015: Manufacturers & importers comply with new SDS and label requirements.
– Dec. 1, 2015: Distributors not to ship unless container has GHS label.
Substantially identical to OSHA’s standard
Phase-in schedule, cont.:
– June 1, 2016: ERs update labels, EE hazard training, and written Haz Com programs.
– Upon completion of the transition period, the existing standard (296-800-170) will be repealed.
Exemptions
All the current exemptions from the rule, and exemptions from labeling, still apply.
One new exemption from the rule:– “Nuisance particulates where the chemical
manufacturer or importer can establish that they do not pose any physical or health hazard covered under this section.”
Major Changes
Labels & SDS
– No longer performance-based.
– Each hazard class and category has specified hazard statement(s), signal word, pictogram(s), and precautionary statement(s) in mandatory Appendix C. Those elements must appear on the label and SDS.
Major Changes
Hazard determination
– Now titled “hazard classification”
– Detailed data-based criteria
• Health hazard criteria in mandatory Appendix A and non-mandatory Appendix F
• Physical hazard criteria in mandatory Appendix B
– Specified; no longer performance-based
Classification of chemical hazards
Hazard class: the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute toxicity.
Hazard category: division by degree or type of hazard within each hazard class.
Hazard Class Hazard Category (health hazard criteria, Appendix A)
Acute toxicity 1 2 3 4
Skin corrosion/irritation 1A 1B 1C 2
Serious eye damage/irritation 1 2A 2B
Respiratory or skin sensitizers 1A 1B
Germ cell mutagenicity 1A 1B 2
Carcinogenicity 1A 1B 2
Reproductive toxicity 1A 1B 2 lactation
Specific target organ toxicity - single exposure
1 2 3
Specific target organ toxicity - repeated exposure
1 2
Aspiration 1
Hazard Class Hazard Category (physical hazard criteria, Appendix B)
Explosive Unstable Div 1.1 Div 1.2 Div 1.3 Flammable gases 1 2
Flammable aerosols 1 2
Oxidizing gases 1 Gases under pressure Compressed Liquefied Refrigerated
liquefiedDissolved
Flammable liquids 1 2 3 4Flammable solids 1 2
Self-reactive A B C D E F GPyrophoric liquids 1Pyrophoric solids 1 Self-heating 1 2Emits flammable gas when in contact with water
1 2 3
Oxidizing liquids 1 2 3Oxidizing solids 1 2 3Organic peroxides A B C D E F GCorrosive to metals 1
Label Requirements
1. Find the hazard class
From Appendix B:
2. Find the hazard category
From Appendix B:
3. Find the required label elements
From Appendix C:
Label pictograms
Exploding Bomb Symbol
Unstable Explosives
Explosives (Divisions 1.1-1.4)
Self-reactives (Type A and Type B with Flame)
Organic Peroxides (Type A and Type B with Flame)
Flame Symbol Flammable Gases Flammable Aerosols Flammable Liquids (Categories 1-3) Flammable Solids Self-Reactives (Type B with bomb, Types
C-F) Pyrophoric liquids and solids Self-heating substances Substances which in contact with water
emit flammable gases Organic Peroxides (Type B with bomb,
Types C-F)
Flame over Circle Symbol
Oxidizing Gases
Oxidizing Liquids
Oxidizing Solids
Gas Cylinder Symbol
Compressed Gas
Liquefied Gas
Refrigerated Liquefied Gas
Dissolved Gas
Corrosion Symbol
Corrosive to Metals (steel or aluminum >6.25 mm/year at 55C)
Skin corrosion/ irritation – Category 1 (A, B and C)
Serious eye damage/ irritation – Category 1
Skull and Crossbones Symbol
Acute Toxicity – Categories 1-3 (oral, inhalation or dermal routes)
Exclamation Mark Symbol Acute Toxicity – Category 4 (oral, inhalation
or dermal routes)
Skin Irritation/ Corrosion – Category 2
Serious Eye damage/ irritation – Category 2A
Skin Sensitizer
Specific target organ toxicity (single exposure) – Category 3 (respiratory tract irritation, narcotic effects)
Hazardous to the Ozone Layer
Health Hazard Symbol
Respiratory Sensitizer
Germ Cell Mutagenicity
Carcinogenicity
Toxic to Reproduction
Specific target organ toxicity (single exposure) – Categories 1-2
Specific target organ toxicity (repeated exposure) – Categories 1-2
Aspiration Hazard
Environment Symbol*
Acute hazards to the aquatic environment – Category 1 (Categories 2 and 3 use no symbol or signal word)
Chronic hazards to the aquatic environment – Categories 1 and 2 (Categories 3 and 4 use no symbol or signal word)
*Part of GHS, but not required by WISHA or OSHA standards.
Hazard statements
Hazard statement is specified for each level of hazard (category) within each hazard class (See Appendix C)
– 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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The text of all applicable hazard statements shall appear on the label.
Hazard statements may be combined where appropriate to reduce the information on the label and improve readability, as long as all of the hazards are conveyed as required.
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Hazard statements
Multiple hazards
The pictogram and signal word used must reflect the most severe hazard category; and all relevant hazard statements must be used.
– If skull and crossbones, no exclamation point for acute toxicity
– If corrosive, no exclamation point for eye/skin irritation
– If health hazard for respiratory sensitization, no exclamation point for skin sensitization or eye/skin irritation
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"Precautionary statement" means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling.
Precautionary statements
There are 4 types of precautionary statements– Prevention– Response– Storage– Disposal
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Precautionary statements
Precautionary statements May be combined or consolidated to save label space
and improve readability.
Where a chemical has multiple hazards and the precautionary statements are similar, the most stringent shall be included on the label.
An order of precedence may be imposed.
If the chemical manufacturer, importer, or responsible party can demonstrate that a precautionary statement is inappropriate to a specific substance, it may be omitted from the label. 37
Supplementary hazard information
Only allowed if it provides further detail and does not contradict or cast doubt on the validity of the standardized hazard information.
Placement shall not impede identification of information required by the Standard.
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Label arrangement Label elements must be located together on the label,
tag or mark. Must not conflict with DOT regulations. Pictograms must have red border. Red frame must be wide enough to be clearly visible. Blank red diamonds are not permitted. Where a DOT label appears on a shipped container,
the same OSHA pictogram shall not appear. Labels must be in English (other languages also
permitted).
1. Product identifier 4. Hazard statement(s)2. Signal word 5. Precautionary statement(s)3. Pictogram(s) 6. Contact info for responsible
party
Potential for confusion
In NFPA 704 and HMIS, “4” = severe hazard In GHS, “4” = low hazard
GHS Category Hazard
1 highest
2 high
3 medium
4 low
HMIS/NFPAIndex Hazard
1 slight
2moderate
3serious
4severe
From the preamble to OSHA’s new standard:“Neither the proposal nor final rule prohibits the use of NFPA or HMIS rating systems.” – Federal Register, 77(58), Monday, March 26, 2012, p. 17758
May confuse employers who need to look up hazard categories.
Most employees won’t notice unless it’s covered in their training, because hazard categories don’t appear on labels or SDSs (only used to determine required label info)
Potential for confusion
Potential for confusion
MATERIAL SAFETY DATA SHEETSSAFETY DATA SHEETS
16-section format now required, similar to the current ANSI format.
Order of the sections is specified.
Specific required information for each section is in mandatory Appendix D.
Environmental provisions are included to be GHS-compliant; DOSH will not enforce (sections 12-15).
SAFETY DATA SHEETS
Safety Data Sheets
Safety Data Sheets Must be in English (additional languages OK)
If there’s no relevant information for a section, it must be marked to indicate no data
Preparer must assure information accurately reflects the scientific evidence used in making the hazard classification
Preparer must update within 3 months of significant new information. If not currently produced, then before shipped again or introduced into the workplace.
SDS distribution
Provide with initial shipment, and with first shipment after update.
Either before or with the shipment, on request.
Retail and wholesale distributors shall post a sign or inform employers that SDSs are available.
New SDS elements
Standardized pictograms, hazard statements, signal words, and precautionary statements
Exact percentages of ingredients are required in most cases; some may still give ranges:– When there is a trade secret claim.
– When a product varies batch-to-batch.
– For a group of substantially similar mixtures with similar chemical composition.
SDS required sections1. Identification2. Hazard(s) identification3. Composition/information on
ingredients4. First-aid measures5. Fire-fighting measures6. Accidental release measures7. Handling & storage8. Exposure control/personal
protection
9. Physical & chemical properties10. Stability & reactivity11. Toxicological information12. Ecological information13. Disposal considerations14. Transport information15. Regulatory information16. Other information
Section 1 - Identification
Product identifier used on the label or other means of identification;
Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party;
Emergency phone number
Section 2 - Hazard(s) identification
Classification of the chemical
Signal word, hazard statement(s), symbol(s) and precautionary statement(s).
Hazard symbols may be provided as graphical reproductions in black and white or the name of the symbol, e.g., flame, skull and crossbones, etc.
Section 3 - Composition / Ingredients
For substances: Chemical name
Common name and synonyms
CAS number and other unique identifiers
Impurities and stabilizing additives which are classified and contribute to the classification of the substance.
For mixtures:
Info required for substances, plus: Chemical name and concentration (exact or
range) of all ingredients which are classified as health hazards and– are present above their hazard class
cut-off/concentration limits; or – present a health risk below the hazard class cut-
off/concentration limits.
Section 3 - Composition / Ingredients
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Section 4 - First-aid measures
Description of necessary measures, subdivided according to the different routes of exposure, i.e., inhalation, skin and eye contact, and ingestion.
Most important symptoms/effects, acute and delayed.
Indication of immediate medical attention and special treatment needed, if necessary.
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Section 5 - Fire-fighting measures
Suitable (and unsuitable) extinguishing media.
Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products).
Special protective equipment and precautions for fire-fighters.
Section 6 - Accidental release measures
Personal precautions, protective equipment, and emergency procedures.
Methods and materials for containment and cleaning up.
Section 7 - Handling and storage
Precautions for safe handling.
Conditions for safe storage, including any incompatibilities.
Section 8 - Exposure Controls/Personal Protection
Permissible exposure limit (PEL), Threshold Limit Value (TLV), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available.
Appropriate engineering controls.
Individual protection measures, such as personal protective equipment.
Appearance (physical state, color, etc.)
Odor Odor threshold pH Melting point/freezing point Initial boiling point and
boiling range Flash point Evaporation rate Flammability (solid, gas)
Upper/lower flammability or explosive limits
Vapor pressure Vapor density Relative density Solubility(ies) Partition coefficient: n-octanol/water Auto-ignition temperature Decomposition temp. Viscosity
Section 9 - Physical and Chemical Properties
Section 10 Stability and Reactivity
Reactivity
Chemical stability
Possibility of hazardous reactions
Conditions to avoid (e.g., static discharge, shock, or vibration)
Incompatible materials
Hazardous decomposition products
Section 11 - Toxicological Information
Description of health effects and the available data used to identify those effects, including:
Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact)
Symptoms related to the physical, chemical and toxicological characteristics
Delayed and immediate effects and also chronic effects from short- and long-term exposure
Section 12 - Ecological Information
Non-mandatory Ecotoxicity (aquatic and terrestrial, where
available) Persistence and degradability Bioaccumulative potential Mobility in soil Other adverse effects (such as hazardous to
the ozone layer).
Section 13 - Disposal Considerations
Non-Mandatory
Description of waste residues and information on their safe handling and methods of disposal, including the disposal of any contaminated packaging.
Section 14 Transport Information
Non-Mandatory UN number UN proper shipping name Transport hazard class(es) Packing group, if applicable Environmental hazards (e.g., Marine pollutant) Special precautions which a user needs to be aware
of in connection with transport or conveyance either within or outside their premises.
Section 15 Regulatory Information
Non-Mandatory
Safety, health and environmental regulations specific for the product in question.
Section 16 - Other Information
The date of preparation of the SDS or the last change
References
Compliance assistance
Effective dates for employers
During the transition period, option to comply with the requirements in the existing rules, or the requirements in the new rule, or both.
June 1, 2014: Train EEs on Safety Data Sheet (SDS) format and new label elements.
June 1, 2016: Update labels, train EEs on new hazards, and update written Chemical Haz Com programs.
Help available from DOSH
Help available from DOSH
Help available from DOSH
Help available from DOSH
Additional help from DOSH
Consultation Services
– Customized training assistance for employers on request.
– Workshops being developed.
Education & Outreach
– Online training modules being developed by Ernesto Carcamo.
GHS-related changes to other standards
GHS requires changes in 25 other standards
1. Wording of hazard signs and labels.
2. Definitions of flammable and combustible materials in multiple standards.
Affects virtually all standards addressing chemical hazards (including PSM, laboratories, spray finishing, dipping, coating, welding, hazardous waste, emergency response, etc.)
GHS requires changes in 25 other standards Welding, Cutting, & Brazing Flammable & Combustible Liquids Spray finishing Shipbuilding, -Repairing & -Breaking Hexavalent Chromium Cotton Dust Coke Ovens Asbestos, Tremolite, Anthophyllite, &
Actinolite Carcinogens Vinyl Chloride Acrylonitrile 1,2-Dibromo-3-chloropropane
Cadmium Butadiene Methylene chloride Lead Methylenedianiline (MDA) Hazardous Chemicals In Laboratories Process Safety Management Dipping & Coating Operations Hazardous Waste Operations Arsenic Benzene Ethylene Oxide Formaldehyde
Other resources
www.osha.gov/dsg/hazcom
www.schc.org
DOSH Specialist on GHS:
Pam Edwards, Industrial Hygienist, MES
DOSH Technical Services, Tumwater
(360) 902-6457
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