Tuesday, July 30, 2013

TLVs, OSHA addressed hazards under HCS not changed by the GHS?

Q. Will TLVs be required on the Safety Data Sheet (SDS)?

A. OSHA is retaining the requirement to include the American Conference of Government Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) on the safety data sheet (SDS) in the revised Standard. OSHA finds that requiring TLVs on the SDS will provide employers and employees with useful information to help them assess the hazards presented by their workplaces. In addition to TLVs, OSHA permissible exposure limits (PELs), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet are also required.

Q. May the International Agency for Research on Cancer (IARC) and the National Toxicology Program (NTP) lists be used to make carcinogen classifications?

A. In the revised HazardCommunication Standard (HCS), OSHA has provided classifiers with the option of relying on the classification listings of IARC and NTP to make classification decisions regarding carcinogenicity, rather than applying the criteria themselves. OSHA believes that this will make classification easier for classifiers, as well as lead to greater consistency. In addition, OSHA has provided in non-mandatory Appendix F of the revised rule, guidance on hazard classification for carcinogenicity. Part A of Appendix F includes background guidance provided by GHS based on the Preamble of the IARC "Monographs on the Evaluation of Carcinogenic Risks to Humans" (2006). Part B provides IARC classification information. Part C provides background guidance from the National NTP "Report on Carcinogens" (RoC), and Part D is a table that compares GHS carcinogen hazard categories to carcinogen classifications under IARC and NTP, allowing classifiers to be able to use information from IARC and NTP RoC carcinogen classifications to complete their classifications under the GHS, and thus the HCS.

Q. Will the International Agency for Research on Cancer (IARC) and the National Toxicology Program (NTP) classifications be required on the Safety Data Sheet (SDS)?

A. OSHA has retained the requirement to include IARC and NTP classifications on safety data sheets (SDSs). Therefore, if a chemical is listed as a carcinogen by either IARC or NTP, it must be noted on the SDS. Additionally, if OSHA finds a chemical to be a carcinogen, it must be noted on the SDS as well. 

Q. How has OSHA addressed hazards covered under the current Hazard Communication Standard that have not been addressed by the GHS?

A. In the Notice of Proposed Rulemaking (NPRM), OSHA proposed to include hazards currently covered under the Hazard Communication Standard (HCS) that have yet to be addressed by the GHS (OSHA provided several examples: simple asphyxiants, and combustible dust) in a separate category called "Unclassified Hazards". In response to comments from the regulated community, OSHA has renamed the category to "Hazards Not Otherwise Classified (HNOC)" to minimize confusion. In the final HCS, HNOC hazards will not be required to be disclosed on the label but will be required to be disclosed in section 2 of the Safety Data Sheet (SDS). This reflects how GHS recommends these hazards should be disclosed. Chemical manufacturers and importers are expected to assess these hazards when they are conducting their hazard evaluation of physical and health hazards. A new or separate evaluation is not required. Also in the final standard, in response to comments, OSHA has removed pyrophoric gases, simple asphyxiants, and combustible dust from the HNOC hazard category and has addressed these chemicals individually (see question below for more information on each hazard).

Friday, July 19, 2013

New Hazard Communication Standard (HCS) questions.

Q. Can I use a black border on pictograms for domestic shipment?

A. Under the revised Hazard Communication Standard (HCS), pictograms must have red borders. OSHA believes that the use of the red frame will increase recognition and comprehensibility. Therefore, the red frame is required regardless of whether the shipment is domestic or international.

Q. Will OSHA allow blank red borders?

A. The revised Hazard Communication Standard (HCS) requires that all red borders printed on the label have a symbol printed inside it. If OSHA were to allow blank red borders, workers may be confused about what they mean and concerned that some information is missing. OSHA has determined that prohibiting the use of blank red borders on labels is necessary to provide the maximum recognition and impact of warning labels and to ensure that users do not get desensitized to the warnings placed on labels.

Q. When must label information be updated?

A. In the revised Hazard Communication Standard (HCS), OSHA is lifting the stay on enforcement regarding the provision to update labels when new information on hazards becomes available. Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information. If the chemical is not currently produced or imported, the chemical manufacturer, importer, distributor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.

Q. How will workplace labeling provisions be changing under the revised Hazard Communication Standard?

A. The current standard provides employers with flexibility regarding the type of system to be used in their workplaces and OSHA has retained that flexibility in the revised Hazard Communication Standard (HCS). Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard. Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers. However, the information supplied on these labels must be consistent with the revised HCS, e.g., no conflicting hazard warnings or pictograms. 

Q. How is the Safety Data Sheet (SDS) changing under the revised Hazard Communication Standard?

A. The information required on the safety data sheet (SDS) will remain essentially the same as that in the current standard. The current Hazard Communication Standard (HCS) indicates what information has to be included on an SDS but does not specify a format for presentation or order of information. The revised HCS requires that the information on the SDS is presented using consistent headings in a specified sequence.

Paragraph (g) of the final rule indicates the headings of information to be included on the SDS and the order in which they are to be provided. In addition, Appendix D indicates what information is to be included under each heading. The SDS format is the same as the ANSI standard format which is widely used in the U.S. and is already familiar to many employees.

Friday, July 12, 2013

How will labels and pictograms change under the revised Hazard Communication Standard?

How will labels change under the revised Hazard Communication Standard?

Under the current Hazard Communication Standard (HCS), the label preparer must provide the identity of the chemical, and the appropriate hazard warnings. This may be done in a variety of ways, and the method to convey the information is left to the preparer. Under the revised HCS, once the hazard classification is completed, the standard specifies what information is to be provided for each hazard class and category. Labels will require the following elements:
  • Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the HCS.
  • Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards.
  • Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
  • Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical.

What pictograms are required in the revised Hazard Communication Standard? What hazard does each identify?

There are nine pictograms under the GHS to convey the health, physical and environmental hazards. The final Hazard Communication Standard (HCS) requires eight of these pictograms, the exception being the environmental pictogram, as environmental hazards are not within OSHA's jurisdiction. The hazard pictograms and their corresponding hazards are shown below.