Friday, November 30, 2012

New Hazard Communication Standard Q & A Part 1

Q. What is the Globally Harmonized System?

A. The Globally Harmonized System (GHS) is an international approach to hazard communication, providing agreed criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets. The GHS was negotiated in a multi-year process by hazard communication experts from many different countries, international organizations, and stakeholder groups. It is based on major existing systems around the world, including OSHA's Hazard Communication Standard and the chemical classification and labeling systems of other US agencies.
The result of this negotiation process is the United Nations' document entitled "Globally Harmonized System of Classification and Labeling of Chemicals," commonly referred to as The Purple Book. This document provides harmonized classification criteria for health, physical, and environmental hazards of chemicals. It also includes standardized label elements that are assigned to these hazard classes and categories, and provide the appropriate signal words, pictograms, and hazard and precautionary statements to convey the hazards to users. A standardized order of information for safety data sheets is also provided. These recommendations can be used by regulatory authorities such as OSHA to establish mandatory requirements for hazard communication, but do not constitute a model regulation.

Q. Why did OSHA decide to modify the Hazard Communication Standard to adopt the GHS?

A. OSHA has modified the Hazard Communication Standard (HCS) to adopt the GHS to improve safety and health of workers through more effective communications on chemical hazards. Since it was first promulgated in 1983, the HCS has provided employers and employees extensive information about the chemicals in their workplaces. The original standard is performance-oriented, allowing chemical manufacturers and importers to convey information on labels and material safety data sheets in whatever format they choose. While the available information has been helpful in improving employee safety and health, a more standardized approach to classifying the hazards and conveying the information will be more effective, and provide further improvements in American workplaces. The GHS provides such a standardized approach, including detailed criteria for determining what hazardous effects a chemical poses, as well as standardized label elements assigned by hazard class and category. This will enhance both employer and worker comprehension of the hazards, which will help to ensure appropriate handling and safe use of workplace chemicals. In addition, the safety data sheet requirements establish an order of information that is standardized. The harmonized format of the safety data sheets will enable employers, workers, health professionals, and emergency responders to access the information more efficiently and effectively, thus increasing their utility.
Adoption of the GHS in the US and around the world will also help to improve information received from other countries—since the US is both a major importer and exporter of chemicals, American workers often see labels and safety data sheets from other countries. The diverse and sometimes conflicting national and international requirements can create confusion among those who seek to use hazard information effectively. For example, labels and safety data sheets may include symbols and hazard statements that are unfamiliar to readers or not well understood. Containers may be labeled with such a large volume of information that important statements are not easily recognized. Given the differences in hazard classification criteria, labels may also be incorrect when used in other countries. If countries around the world adopt the GHS, these problems will be minimized, and chemicals crossing borders will have consistent information, thus improving communication globally.

Tuesday, November 20, 2012

Hazard Communication Standard: Safety Data Sheets - Sections 15-16

Section 15: Regulatory Information (non-mandatory)
This section identifies the safety, health, and environmental regulations specific for the product
that is not indicated anywhere else on the SDS. The information may include:
• Any national and/or regional regulatory information of the chemical or mixtures (including any
OSHA, Department of Transportation, Environmental Protection Agency, or Consumer Product
Safety Commission regulations).
Section 16: Other Information
This section indicates when the SDS was prepared or when the last known revision was made.
The SDS may also state where the changes have been made to the previous version. You may
wish to contact the supplier for an explanation of the changes. Other useful information also may
be included here.

Employer Responsibilities

Employers must ensure that the SDSs are readily accessible to employees for all hazardous chemicals in their workplace. This may be done in many ways. For example, employers may keep the SDSs in a binder or on computers as long as the employees have immediate access to the information without leaving their work area when needed and a back-up is available for rapid access to the SDS in the case of a power outage or other emergency. Furthermore, employers may want to designate a person(s) responsible for obtaining and maintaining the SDSs. If the employer does not have an SDS, the employer or designated person(s) should contact the manufacturer to obtain one.

If you are needing safety training materials to ensure compliance with the new OSHA Hazard Communication Regulation 29 CFR 1910.1200, please contact National Safety Compliance, Inc. at 1-877-922-7233 or www.osha-safety-training.net

Friday, November 9, 2012

Hazard Communication Standard: Safety Data Sheets - Sections 12-14

Section 12: Ecological Information (non-mandatory)
This section provides information to evaluate the environmental impact of the chemical(s) if it
were released to the environment. The information may include:
• Data from toxicity tests performed on aquatic and/or terrestrial organisms, where available
(e.g., acute or chronic aquatic toxicity data for fish, algae, crustaceans, and other plants; toxicity
data on birds, bees, plants).
• Whether there is a potential for the chemical to persist and degrade in the environment either
through biodegradation or other processes, such as oxidation or hydrolysis.
• Results of tests of bioaccumulation potential, making reference to the octanol-water partition
coefficient (Kow) and the bioconcentration factor (BCF), where available.
• The potential for a substance to move from the soil to the groundwater (indicate results from
adsorption studies or leaching studies).
• Other adverse effects (e.g., environmental fate, ozone layer depletion potential, photochemical
ozone creation potential, endocrine disrupting potential, and/or global warming potential).
Section 13: Disposal Considerations (non-mandatory)
This section provides guidance on proper disposal practices, recycling or reclamation of the
chemical(s) or its container, and safe handling practices. To minimize exposure, this section
should also refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS.
The information may include:
• Description of appropriate disposal containers to use.
• Recommendations of appropriate disposal methods to employ.
• Description of the physical and chemical properties that may affect disposal activities.
• Language discouraging sewage disposal.
• Any special precautions for landfills or incineration activities.
Section 14: Transport Information (non-mandatory)
This section provides guidance on classification information for shipping and transporting of
hazardous chemical(s) by road, air, rail, or sea. The information may include:
• UN number (i.e., four-figure identification number of the substance)2.
• UN proper shipping name2.
• Transport hazard class(es)2.
• Packing group number, if applicable, based on the degree of hazard2.
• Environmental hazards (e.g., identify if it is a marine pollutant according to the International
Maritime Dangerous Goods Code (IMDG Code)).
• Guidance on transport in bulk (according to Annex II of MARPOL 73/783 and the International
Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk
(International Bulk Chemical Code (IBC Code)).
• Any special precautions which an employee should be aware of or needs to comply with, in
connection with transport or conveyance either within or outside their premises (indicate
when information is not available).

Monday, November 5, 2012

Hazard Communication Standard: Safety Data Sheets - Sections 9-11

Section 9: Physical and Chemical Properties
This section identifies physical and chemical properties associated with the substance or mixture.
The minimum required information consists of:
• Appearance (physical state, color, etc.); • Upper/lower flammability or explosive limits;
• Odor; • Vapor pressure;
• Odor threshold; • Vapor density;
• pH; • Relative density;
• Melting point/freezing point; • Solubility(ies);
• Initial boiling point and boiling range; • Partition coefficient: n-octanol/water;
• Flash point; • Auto-ignition temperature;
• Evaporation rate; • Decomposition temperature; and
• Flammability (solid, gas); • Viscosity.
The SDS may not contain every item on the above list because information may not be relevant
or is not available. When this occurs, a notation to that effect must be made for that chemical
property. Manufacturers may also add other relevant properties, such as the dust deflagration
index (Kst) for combustible dust, used to evaluate a dust's explosive potential.
Section 10: Stability and Reactivity
This section describes the reactivity hazards of the chemical and the chemical stability
information. This section is broken into three parts: reactivity, chemical stability, and other.
The required information consists of:
Reactivity
• Description of the specific test data for the chemical(s). This data can be for a class or family
of the chemical if such data adequately represent the anticipated hazard of the chemical(s),
where available.
Chemical stability
• Indication of whether the chemical is stable or unstable under normal ambient temperature
and conditions while in storage and being handled.
• Description of any stabilizers that may be needed to maintain chemical stability.
• Indication of any safety issues that may arise should the product change in physical
appearance.
Other
• Indication of the possibility of hazardous reactions, including a statement whether the chemical
will react or polymerize, which could release excess pressure or heat, or create other hazardous
conditions. Also, a description of the conditions under which hazardous reactions may occur.
• List of all conditions that should be avoided (e.g., static discharge, shock, vibrations, or
environmental conditions that may lead to hazardous conditions).
• List of all classes of incompatible materials (e.g., classes of chemicals or specific substances)
with which the chemical could react to produce a hazardous situation.
• List of any known or anticipated hazardous decomposition products that could be produced
because of use, storage, or heating. (Hazardous combustion products should also be included
in Section 5 (Fire-Fighting Measures) of the SDS.)
Section 11: Toxicological Information
This section identifies toxicological and health effects information or indicates that such data
are not available. The required information consists of:
• Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact).
The SDS should indicate if the information is unknown.
• Description of the delayed, immediate, or chronic effects from short- and long-term exposure.
• The numerical measures of toxicity (e.g., acute toxicity estimates such as the LD50 (median
lethal dose)) - the estimated amount [of a substance] expected to kill 50% of test animals in a
single dose.
• Description of the symptoms. This description includes the symptoms associated with
exposure to the chemical including symptoms from the lowest to the most severe exposure.
• Indication of whether the chemical is listed in the National Toxicology Program (NTP)
Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the
International Agency for Research on Cancer (IARC) Monographs (latest editions) or found
to be a potential carcinogen by OSHA.